1 Thursday, 19 January 2023 2 (10.00 am) 3 MS KENNEDY: Good morning, Chair. 4 SIR WYN WILLIAMS: Good morning. 5 MS KENNEDY: Our first witness today and only witness today 6 is Mr Donald Grey. 7 SIR WYN WILLIAMS: Good morning, Mr Grey. 8 THE WITNESS: Good morning, sir. 9 DONALD SCOTT GREY (sworn) 10 Questioned by MS KENNEDY 11 Q. Could you confirm your full name, please. 12 A. Yes. Donald Scott Grey. 13 Q. Mr Grey, do you have a copy of your witness statement in 14 front of you? 15 A. I do, yes. 16 Q. If you turn to page 25 of that statement, is that your 17 signature there? 18 A. Actually it's page 24 on my copy. 19 Q. You are quite right. Is that your signature there? 20 A. It is, yes. 21 Q. Have you read through this statement recently? 22 A. Yes. 23 Q. And is it true to the best of your knowledge and belief? 24 A. Indeed. 25 Q. That statement is now in evidence. Everything that 1 1 I ask you is supplementary. First, thank you very much 2 for preparing a witness statement and for coming to give 3 evidence today. I'm going to start by asking you a few 4 questions about your background. You joined the 5 Post Office in 1963 as an executive officer; is that 6 right? 7 A. Yes. 8 Q. From 1986 to June 1993 you were district manager for the 9 Post Office; is that right? 10 A. Yes, that's right. 11 Q. What did that role involve? 12 A. That was looking after post offices across four counties 13 in the north Midlands. I can't remember how many there 14 were at the time, must have been about 300. 15 Q. In June 1993 you moved to Leeds on business 16 reorganisation and you became regional general manager 17 for the North-east region; is that right? 18 A. Yes. That was later. I did another role before 19 I became regional manager. That was in 1997. 20 Q. You're quite right. Then as part of your time in that 21 position you were involved in a live trial on Horizon; 22 is that correct? 23 A. Yes. Some of my officers were actually involved in the 24 early part of Horizon but not right at the outset. 25 Q. What was your experience of that like? 2 1 A. It was very much a business-as-usual role in many 2 respects. This was a slightly different take on what we 3 were normally doing in post offices. But clearly there 4 were issues that we had to monitor there to make sure 5 that we were supporting the team in actually rolling out 6 Horizon and learning from the opportunity that this 7 trial gave us. 8 Q. Did you feel that it was a positive, negative experience 9 or neutral? 10 A. I think it was mixed. I think there was general 11 acceptance that it was an opportunity to modernise the 12 business, but it didn't come without its problems. 13 Q. Is that the feedback that you were receiving from 14 subpostmasters at that time? 15 A. Yes, indeed. Yes, it was fairly positive but there were 16 some things that really needed to change to make things 17 better. 18 Q. In summer 1999 you undertook a project to improve the 19 efficiency of the branch office network; is that right? 20 A. That's right. That lasted for a few months, yes. 21 Q. What did that involve? 22 A. It was really working with the unions to try and find 23 a way of reducing the costs that the branch office 24 network was incurring for the business. 25 Q. In January 2000 you were appointed as Horizon National 3 1 Roll Out Project Manager. Can you tell us a bit about 2 that role? 3 A. Well, in that particular role I was not responsible for 4 the whole of the Horizon project but just for the 5 preparation, the training and the installation across 6 the network. Others were responsible for the live 7 environment, contract management, software acceptance 8 and business assurance and other aspects. 9 Q. Then in July 2001 you moved to lead the Business Service 10 Management function; is that right? 11 A. Yes, that's when the Horizon national rollout project 12 had effectively finished. 13 Q. What did that role involve? 14 A. That was lead on the provision of supplies and support 15 to the Post Office network, and it included supply 16 management of internal Post Office partners, such as 17 Cashco stores and customer management, as well as the 18 ICL Horizon Helpdesk. 19 Q. You then retired in March 2003; is that right? 20 A. Yes. It's the best job I've ever had. 21 Q. When you took over, going back to the role of Horizon 22 National Roll Out Project Manager, did you have 23 a handover from David Miller and his team? 24 A. Not that I recall. I did have quite a lot of 25 discussions with people who were involved in the project 4 1 directly at that point in time, but I don't recall any 2 direct discussion with Dave Miller himself. 3 Q. What did those discussions involve? 4 A. It was really an update on what the situation was to 5 date, because I had been out of the scene as far as 6 Horizon was concerned for a few months and, of course, 7 there was a lot happening at that point in time before 8 the system had been accepted and national rollout could 9 continue. 10 Q. Were you ever made aware of the project mentors' report? 11 A. Sorry, the what? 12 Q. Project mentors' report. Have you ever heard of it? 13 A. It doesn't ring any bells, sorry. 14 Q. When you took over in January 2000, were you aware of 15 any problems with EPOSS or the Electronic Point of Sale? 16 A. Not directly. I knew there were certain Acceptance 17 Incidents that had been the subject of discussion 18 between the Post Office and ICL but not specifically 19 about EPOSS. 20 Q. If we could turn up the first document, please. That's 21 POL00090457 -- it should come up on your screen in a 22 moment -- we can see here that this is an email and 23 you're on the distribution list. I think you're halfway 24 down. This is an email from Jonathan Rogers and if we 25 turn over to page 3, we can see that this is a BSM -- so 5 1 that's a Business Service Management snapshot report. 2 We can see that this is a report setting out issues with 3 cash account balances on Wednesday, 21 July from two 4 live trial outlets. Looking beside the second 9, it 5 says: 6 "Offices reported losses and gains three of which 7 may have been migration errors", and it sets out the 8 figures of total loss discrepancy and total gain 9 discrepancy. 10 Before you took over your role you had received 11 emails setting out that there were issues with 12 discrepancies in terms of cash account balancing; is 13 that right? 14 A. I don't recall that in fairness, no. 15 Q. Did you receive a lot of emails like this at the time? 16 A. I can't recall a number, but it was quite common that we 17 were kept in the loop about things that were happening. 18 Q. That document can come down, please. 19 If we could turn up POL00028463, this is another 20 email from September 1999 -- so again before you took 21 over as the project manager -- and we can again see your 22 name midway through the distribution list. It's an 23 email from, I think, Keith Hardie which we can see if we 24 turn over to page 2 and looking at that first paragraph. 25 It says: 6 1 "As you know, we have been going through the 2 acceptance process for Horizon, while ICL work on some 3 technical issues that emerged during the trial. I am 4 pleased to say progress has been made on these issues 5 and, as a result, we have now been able to agree to 6 installing the equipment in a further 336 offices from 7 20 September, on top of the 150 offices we had already 8 agreed to. This will bring the total number of offices 9 in the trial to some 810, and I will update you on 10 further news as it is available. Please feel free to 11 communicate this information to your teams if they want 12 an update on the latest position." 13 If we scroll down, we can see that you're given 14 a public line about the reasons for this and if we look 15 at the 5th bullet point, it says: 16 "If asked about what the issues are, we are going 17 through a difficult phase in the Horizon discussions. 18 As a result it wouldn't be appropriate for us to discuss 19 the details of the issues publicly, but we are hoping 20 they will be resolved quickly and we will then be able 21 to resume offering the service in all Horizon offices." 22 So at this time again there seems to be a lot of 23 discussion about issues that have been identified with 24 the system that you're being copied into. 25 A. Yes. I think I'd moved off the general manager role at 7 1 that point, and I was actually doing the branch office 2 efficiency project. So although I was copied into that 3 particular email, it wasn't of great relevance to me at 4 that point in time. 5 Q. So did you find that you were being copied in on things 6 that didn't specifically require your attention at this 7 time? 8 A. I can't recall, but it wouldn't surprise me. 9 Q. Turning forward then to when you take over the role of 10 the project manager in January 2000, if we can turn up 11 NFSP00000261, and if we could turn to page 7. This is 12 the Christmas Horizon Research Report which we've turned 13 to a number of times in this Inquiry. It was written by 14 Lorna Green in January 2000. So this is right that time 15 you take over in this role, isn't it? 16 A. That's right, yes. 17 Q. If we turn to page 9, this gives the results of the 18 telephone interviews. As it sets out in the 19 introduction: 20 "This report gives the results of 330 telephone 21 interviews with staff and agents whose offices have 22 taken part in the Horizon roll out in the autumn of 23 1999. In these interviews they were asked their opinion 24 on different aspects of the Horizon System, and various 25 types of support available (including manuals and 8 1 Helpdesks) and their overall satisfaction with the 2 automation programme." 3 Under Results and Conclusions, it says: 4 "Results on almost all aspects of Horizon are 5 mixed. Some staff and subpostmasters are getting to 6 grips with the system and are happy and satisfied while 7 others are struggling and continuously having problems. 8 There are no obvious pattern by office type, IP area, 9 number of counter positions or the length of time since 10 migration. 11 "However where comparisons have been possible, 12 these results are more favourable than the results from 13 the live trial ... last June." 14 Looking at the next paragraph, it says: 15 "The main message coming through is that they are 16 not getting enough training. They are mainly happy with 17 what the one-and-a-half days they received, but the 18 training on balancing is not long enough for their 19 needs." 20 Scrolling down to the bottom of that page, it 21 says: 22 "The other area for concern is Helpdesks. There 23 is confusion over which number to call, which is 24 compounded by them being passed back and forth between 25 Helpdesks. There is a problem getting through to the 9 1 Horizon system Helpdesk in particular and the service 2 from both appears to be lacking in terms of consistency 3 and ... knowledge." 4 So there were big issues from the very beginning 5 of your tenure about training and the Helpdesk; is that 6 right? 7 A. Yes, yes, and it's perhaps not surprising that these 8 situations happened because everybody was learning at 9 the same time as we introduced Horizon into the 10 business. 11 Q. If we turn to page 13 of that report, the objectives of 12 the report are set out and the objectives of the 13 research. It says: 14 "The objective of the research was to evaluate how 15 these 1856 offices have found the Horizon System, in 16 order to identify any potential problems before national 17 roll out commences. The major aspects of Horizon were 18 to be covered, including the various types of support 19 available." 20 Did you understand or did you speak to anyone 21 before this report was commissioned? 22 A. No, because it had been commissioned and completed 23 before I actually joined the project. 24 Q. Did you know anything about why this research was done? 25 Were there any particular concerns that people were 10 1 aware of prior to its commission? 2 A. I suspect there may have been, but this report was 3 really good background information. It gives 4 a benchmark on which to build and to actually identify 5 any issues that were current and needed attention, and 6 there were a number of actions which ensued from this 7 report to actually improve things for everyone. 8 Q. Turning to page 15, we can see the results of training 9 there. It says: 10 "Opinion was split on the training with 11 50 per cent saying that the training was good and 12 50 per cent saying it was poor. This was similar to the 13 results from the live trial research except that this 14 time there are more respondents in the very poor 15 category." 16 So this is really quite concerning, isn't it, the 17 feedback that you were getting about training at this 18 stage? 19 A. It was and, as a consequence, there were a number of 20 steps that were taken to improve the situation. 21 Q. Turning over to page 16 and scrolling down, looking at 22 Balancing, it says: 23 "Nearly a fifth of respondents are finding 24 balancing using Horizon very difficult and a further 25 quarter, 24 per cent, are finding it fairly difficult." 11 1 So balancing again there's a is a big problem, 2 isn't it? 3 A. Yes. 4 Q. Turning to page 20 -- it might be helpful to go back 5 over the page to page 19 -- and scrolling down, please, 6 this is to do with Helpdesks. It records there's some 7 confusion over which Helpdesk to call which has 8 deteriorated since the live trial. Back over to 9 page 20, it seems 59 per cent are satisfied with the 10 Helpdesk to some extent. 11 So again this is quite negative feedback, isn't 12 it? 13 A. It was and it perhaps supported the fact that one of the 14 Acceptance Incidents that was being debated before 15 I joined the project was related to the performance of 16 the Horizon System Helpdesk. 17 Q. Turning to page 26, please, and scrolling down, it 18 summarises the conclusions: 19 "Results on almost all aspects of Horizon are 20 mixed. Some staff and subpostmasters getting to grips 21 with the system are happy and satisfied but others are 22 struggling and continuously having problems." 23 Again, the third paragraph, the main message is 24 coming through that they are not getting enough 25 training. 12 1 So when you got this report, what did you decide 2 to do in light of it? 3 A. Well, some steps had already been taken. For example, 4 in the second supplementary agreement, there'd been 5 a move to increase the training by providing 6 a user-awareness event, some two to four weeks before 7 they actually went through training itself. This was to 8 really introduce learning as a process rather than as an 9 event, and it became a gradual introduction to Horizon. 10 Beyond that, there were improvements made in the 11 balancing process. We diverted more staff to actually 12 supporting offices during the rollout period and in the 13 weeks thereafter, and we introduced a balancing guide as 14 well which, again, was another tool to actually making 15 balancing easier for them. 16 As a consequence, we actually took the score from 17 what was 19 per cent on ease of balancing in the live 18 trial right up to 90 per cent within 12 months. 19 Q. If we could turn to the next document, please, which is 20 POL00028441, this is an email from the author of the 21 report and we can see in the second paragraph of her 22 email, she says: 23 "I strongly recommend that you take time to browse 24 through the staff and subpostmasters' own words as it 25 provides insight into their strength of feeling about 13 1 various aspects of Horizon." 2 Was that message heard by you and other people in 3 the Post Office? 4 A. Absolutely. I mean, we didn't go around with our eyes 5 and ears shut. We were very alert to feedback like this 6 because it was so important to us in trying to get 7 things right. 8 Q. Turning to 20 January 2000, if we could pick up 9 POL00028509, this is an email from 20 January. This was 10 shortly after you started in the post; is that right? 11 A. That's right, it is. 12 Q. And we can see you're on the distribution list and this 13 is from a Dick Brazear. Then if we can turn over the 14 page, these are the notes of a Horizon Pathway delivery 15 meeting on 14 January and, if we can scroll down, 16 please, it says at paragraph 2: 17 "Dave Smith summarised the key areas which were at 18 issue for the continuation of roll out on 24 January. 19 These were: the rectification of outstanding data 20 integrity weaknesses, AI 376/3; the clarification and 21 resolution of weaknesses in Helpdesk performance, AI 22 408/3; the resolution of issues with the management of 23 reference data, and the satisfactory deployment and 24 operation of integrity control. 25 "He identified that for each of these areas there 14 1 was now an agreed way forward and that robust checks had 2 been in place to address the original concerns. However 3 there were still further checks to be completed by TIP 4 on the deployment of the integrity control. Further 5 work also needed to be done between Horizon Commercial 6 and ICL Pathway on reaching contractual agreement on the 7 third supplemental agreement." 8 So there you are being made aware of the issues 9 with the system and potential data integrity issues, 10 aren't you? 11 A. Yes. 12 Q. At this -- 13 A. We had those before as well, because they had been part 14 of the communications that I'd received when I was in 15 the regional general manager post. 16 Q. So, when you were deciding what to do in relation to 17 training, especially in respect of balancing, did you 18 ever think: well, hold on a second, maybe there's 19 something going wrong with the system rather than 20 subpostmasters not being able to balance properly? 21 A. In fairness, it wasn't my role to engage with that 22 particular problem. This was a business assurance 23 problem and it was for others to track that and identify 24 it. 25 Q. So -- 15 1 A. Clearly we had to know about it because we didn't want 2 to be rolling out a defective system, and at no time did 3 we think we were doing so. 4 Q. But you didn't feel it was your role to escalate 5 concerns; that was for someone else? 6 A. No, because I didn't see those concerns directly. So, 7 as I say, it was for others to pursue those. 8 Q. That document can come down now. 9 If we could turn up NFSP00000348, please, this is 10 a letter to the NFSP, the head of the NFSP, Mr Colin 11 Baker, on 1 February 2000, so again shortly after you 12 took up the role. How did you find working with Colin 13 Baker of the NFSP? 14 A. Fine. I had absolutely no problem. We knew each other 15 in the past and we were both very positive about what we 16 were trying to do. Colin was very forthright, like so 17 many others in the Federation of Subpostmasters, but we 18 were always constructive in the way that we tried to 19 resolve things. 20 Q. Did you find dealing with the NFSP helpful? 21 A. Indeed. I mean, we couldn't have done this project 22 without their involvement. 23 Q. If we could look, turning back to the document, if we 24 could scroll down to the second paragraph, it says: 25 "Since we paused roll out in November we have 16 1 taken a number of improvements to build on past 2 experiences and provide the robust arrangements we would 3 all like to see to support a programme of around 300 4 outlets a week coming on stream. I note that Dave Smith 5 has outlined most of these in his letter on 31 January, 6 so I will not repeat here. Suffice to say, if you need 7 more detail on any of these, please let me know. 8 "Hopefully these improvements will have an 9 evidenced beneficial effect and tackle the problems 10 identified in the pre-Christmas research that was done 11 via 335 telephone interviews with staff and agents who 12 were involved in Horizon roll out during last autumn." 13 Picking it further down the paragraph: 14 "The research also showed [this is the fourth line 15 from the bottom] that many more would like more training 16 and balancing is still difficult for too many. 17 Certainly we will need to continue to monitor the 18 position as we go through the programme and respond to 19 prevailing requirements as appropriate." 20 Turning over the page and scrolling down, we can 21 see that there are a number of issues raised about the 22 Helpdesk, and then there are a number of specific issues 23 that have previously been raised by the NFSP; is that 24 right? You can see those at (a) to(e). 25 A. Yes. 17 1 Q. Did you feel at this time when you first took over the 2 role the NFSP were raising a lot of problems with the 3 system with you? 4 A. They were raising a lot of problems with rollout rather 5 than the system as such, in fairness. 6 Q. What problems were they raising about rollout? Are they 7 recorded here? 8 A. Well, for example, item (b) there is about training and 9 that was about scheduling of training, I suspect. 10 Q. Rather than the quality of the training itself? 11 A. At that point, yes. 12 Q. Did anyone at the NFSP ever raise any data integrity 13 issues with you? 14 A. Not that I recall, no, because that would have been 15 proper to have dealt with Business Service Management on 16 that one, or transaction processing. 17 Q. That document can come down, please. 18 Turning forward slightly, if we could turn up NFSP 19 00000287 and if we could -- thank you. We've got an 20 email from a Mike Ingle on 3 February 2000 to you and 21 this concerns losses at Waterloo Road. Who was Mike 22 Ingle? 23 A. Mike Ingle was the retail network manager in the Leeds 24 cluster, and he worked for me when I was regional 25 general manager in the north-east. 18 1 Q. Actually, if we just read what this is about, it says: 2 "The losses at this office were discussed at 3 a review and authorised under our normal procedure for 4 dealing with eight-week requests. From memory two of 5 the losses totalling about 1,100 were known to be 6 awaiting an error notice, and authority to hold these 7 beyond 8 weeks was given. The large loss for about 8 £3,000 was the subject of frequent discussions with the 9 subpostmaster who could not accept that this was 10 a genuine error and not down to Horizon." 11 Then picking it up again on the final paragraph, 12 it says: 13 "It is debatable as to whether this was due to 14 operator error or a glitch in the system. There is no 15 evidence either way. The net result is that most of 16 this large loss was accounted for." 17 Why was Mike Ingle bringing this to you? 18 A. I suspect he was responding to an invitation which 19 I issued to everybody that I dealt with, to actually 20 flag up any issues that were of concern to them. There 21 was a recognised route for doing so via the Business 22 Service Management team, but I was also interested in 23 knowing if there were any issues out there. So anything 24 I could do to encourage feedback I did so. 25 Q. You said a moment ago that you were nothing to do with 19 1 the system itself. So why were you taking issues or, 2 you know, hearing feedback in relation to the system? 3 Did you not clearly delineate those with the people you 4 were speaking to? 5 A. I was happy for them to come to me, but I always made 6 sure that they were fed into service management so that 7 they could process them in the normal way of things. It 8 certainly was important that we encouraged people to 9 tell us whenever there were suspected issues out there. 10 Q. Do you remember receiving this email? 11 A. I don't remember it, to be -- in fairness, because, 12 I mean, I must have received a number at the time and it 13 is a long time ago. But it struck a chord when I read 14 it. 15 Q. Do you remember receiving any other emails like this? 16 A. Oh, I'm sure I did, but I couldn't begin to tell you 17 what they were at this point in time. 18 Q. Are there emails about the integrity of the system as 19 opposed to the performance of rollout? Do you think 20 there may have been others? 21 A. There may have been others. As regards what the subject 22 was, I don't know. The important thing was that we 23 wanted people to share with us any concerns they had, 24 whether it was rollout, whether it was system issues or 25 whatever, because we wanted to get this thing right. 20 1 The integrity of the business really depended on us 2 doing so. 3 Q. I appreciate you can't remember, but what do you think 4 you would have done with an email like this? 5 A. With an email like this, I would have probably passed it 6 to one of my team to follow through, one, to make sure 7 it was on the Business Service Management radar and was 8 being followed to solution and, secondly, to make sure 9 that there was sort of some feedback down the line as 10 well. But the important thing was that we had processes 11 in place which were actually there, designed to actually 12 tackle problems like this whenever they were flagged up 13 to us. 14 Q. Moving forward to May 2000, if we could turn up 15 FUJ00075726, this is a diary note of the National 16 Federation of Subpostmasters Annual Conference. Did you 17 attend many events with the NFSP? 18 A. Yes, I did do. I mean, not necessarily on a national 19 scale but perhaps on a more local scale. I think this 20 was probably the only time I spoke to their national 21 conference. 22 Q. Were you the person of contact in relation to the 23 Horizon rollout at Post Office for the NFSP at this 24 time? 25 A. It seemed to be so, yes, yes. I mean, they were 21 1 encouraged to speak to others in the team and not just 2 to me. It wasn't a one-man band by any means, and I had 3 four regional teams across the country, so there was 4 many contacts at regional level between the Federation 5 and my team. 6 Q. Then would those teams then feed back any issues to you? 7 Would they kind of filter up to you as the head of it? 8 A. Sure, if they were relevant to do so. Some of them 9 perhaps could have been sorted out at their level. 10 Q. Turning back to the document, if we could turn over to 11 page 2 and scrolling down, and down again, we can see 12 that you gave a presentation at this meeting. Do you 13 remember that presentation? 14 A. To be honest with you, I'd forgotten all about the event 15 altogether until Alan Johnson gave his testimony a few 16 weeks ago, but I have seen the transcript of the speech 17 I gave which is the subject of another paper that you 18 sent me. 19 Q. What can you tell us about this presentation? What was 20 the purpose of giving it? 21 A. The purpose was to give an update on where we were, to 22 give some positive messages, to recognise that there 23 were problems, and to assure them that we were actually 24 dealing with them, but to put it in the context of how 25 important Horizon was for the benefit of the business 22 1 and subpostmasters. 2 Q. What was the atmosphere like in your mind at this 3 meeting? 4 A. Well, we started off on a fairly jovial note, and there 5 were some hard-hitting questions as well. I mean, it 6 was quite a relaxed sort of session but, at the same 7 point in time, some very serious business went on. 8 Q. We can see in bullet point form the presentation that 9 you gave there on the page and, if we turn over, we can 10 see "Training", and under Training you: 11 "Reported that postmasters wish to extend managers 12 course to the two days. However, Post Office believe 13 this is not the case. For Don [that's you] having 14 spoken to postmasters personally during site visits and 15 even the night before, no-one could state why they 16 needed the extra time." 17 Do you remember saying words to that effect? 18 A. Well, not entirely, no, but what I would point out -- 19 that this is a Fujitsu or ICL version of what I actually 20 said. It would be far more accurate to actually have 21 a look at what I said to the conference, which is the 22 subject of another paper. I think it's NFSP 00000436 23 from memory. 24 Q. But sticking with your memory -- we may turn that up in 25 due course -- did you feel like subpostmasters were 23 1 asking for extra time and that this was unnecessary? 2 A. No, I didn't. No, I mean, I understood the concerns, 3 and we addressed those concerns in what we'd actually 4 put in place earlier in that year. 5 Q. Turning down to the bottom of the page, you mentioned 6 some of the serious issues that were being raised, and 7 we can see here on the Q and A session, it says: 8 "When Leeds and Wakefield went live, 44 outlets, 9 they were all promised support officers. 17 did not 10 show, which caused major problems in the first week of 11 balancing. Why offer or promise something and then not 12 delivery?" 13 Then number 2: 14 "Mid-Glamorgan is due to go live in June. Two 15 points for reference. Phone call regarding training 16 received before letter, and how to write four letters 17 before receiving confirmation about installation date. 18 Fault is bad communication." 19 Third, two points: 20 "Helpdesk don't know the answer to questions when 21 the phone is answered, which is not very often, usually 22 just rings and rings, and management of training is 23 appalling. Trainers know nothing about running a post 24 office." 25 Turning over the page, we can see some further 24 1 issues there. How confident did you feel with dealing 2 with some of these concerns that were raised? 3 A. Well, I didn't duck any of them. Clearly I didn't know 4 all the detail as well as those who were raising the 5 issues, but it wasn't surprising that there were 6 problems across the project given the scale of it, and 7 I'm not surprised that some of these things happened. 8 Q. Turning forward again slightly in time to 18 May 2000, 9 NFSP -- 10 SIR WYN WILLIAMS: Before we do that, could you just remind 11 me whose diary note is this? 12 MS KENNEDY: This diary note is from Fujitsu. We can find 13 that out. 14 SIR WYN WILLIAMS: Yes. I'd like to know who it was exactly 15 who made this diary note if I could. 16 MS KENNEDY: Yes. We'll find that out. Thank you, sir. 17 Moving on to NFSP 00000332, in this email you're 18 copied into an email about polling problems. Do you 19 remember what polling problems were? 20 A. Indeed, yes. These were problems when the ICL server 21 couldn't in fact collect information from the Riposte 22 message store in outlets for it to be then processed by 23 back-end systems and client systems. 24 Q. How concerned were you about this as a problem? 25 A. I was concerned about it, and it was the subject of 25 1 discussions that we had with ICL ourselves, even before 2 this problem manifested itself -- on this occasion that 3 is. It was a big problem in the sense, particularly 4 with clients who -- sorry, customers rather who had 5 actually paid bills and whose record that they'd 6 actually paid that bill was not then being processed by 7 the appropriate client. 8 Q. It sets out in this letter what the Federation would 9 like to see, if we scroll down. Is this an instance of 10 Colin Baker raising something urgently with you to 11 investigate? 12 A. No, this wasn't raised with me directly. This was 13 raised by somebody else. 14 Q. And then copied in to you? 15 A. And then copied in to me, yes. 16 Q. Is this the kind of thing you would have taken forward? 17 A. Absolutely. We couldn't have let this one pass by 18 because of the significance of it. 19 Q. In this email, it mentions the NBSC. We're coming to 20 the NBSC but can you explain what that was and what your 21 view of the NBSC was. 22 A. The NBSC was the call centre that handled calls from 23 Post Office outlets around transactions and accounting, 24 and any issue which they identified was something that 25 constituted a problem they would create an incident on. 26 1 These incidents would be then passed to the Business 2 Service Management team who looked after service 3 management issues for them to pursue to a conclusion. 4 Q. If we could take that document down, please. 5 During that year of 2000, there was also the 6 development of a software update of the CSR+ release. 7 Could you tell us about that software release, please. 8 A. This is the first major release since I joined the 9 project, and it was designed to improve functionality on 10 a number of matters, for example, smartcards, Quantum 11 gas, links with a logistic (unclear) service and a 12 number of other things, but it also importantly actually 13 reduced the rollover time between cash accounts where 14 was a big thorn in the side of postmasters. 15 Q. Did you feel like the release was being rolled out or 16 developed quite soon after the project itself was rolled 17 out? Did you have any concerns about how quickly it was 18 being introduced? 19 A. Not really, no. I was more concerned about doing it 20 alongside rollout and also to ensure that it was done 21 properly as well. There was quite a bit of information 22 that had to be digested by subpostmasters, and that was 23 the subject of some training breaks and workbooks. 24 Q. If we could turn up NFSP00000301, please, this is 25 a letter that you wrote to the NFSP on 3 August 2000, 27 1 Scrolling down, and under the first heading it says: 2 "The roll out of Horizon continues to progress 3 well and is currently ahead of schedule. The 4 development of our next software release, CSR+, has also 5 been progressing well against a very stretching plan. 6 This release extends Horizon to include Smartcard 7 capability, a link to distribution systems to enable 8 improved provisioning of cash and stock and significant 9 upgrades to the infrastructure to improve system 10 manageability and security. 11 "A process of reviewing the outputs of testing and 12 the readiness of both Post Office Network and ICL 13 Pathway to begin a trial of CSR+ in 300 outlets has just 14 been concluded. The objective of the process was to 15 ensure that the software release could be introduced 16 into the business without compromising our day to day 17 operations. Now that Horizon is live in more than half 18 the network, the process is particularly critical." 19 Did you feel that you were being put under 20 pressure or there was pressure to roll out this 21 additional release? 22 A. Well, there was obviously pressure of sorts because this 23 was different to the standard work that we were doing. 24 So we had to make sure that it was right and rolled out 25 properly so that there was no compromise to what we were 28 1 doing. 2 Q. If we scroll down again it says: 3 "ICL have identified a number of outstanding 4 faults related to infrastructure enhancements that could 5 create significant problems in the live environment if 6 CSR+ was introduced without them being fixed. They have 7 advised that the start of the pilot should be postponed. 8 We are fully in agreement with this recommendation." 9 If we could take that document down and move 10 forward to NFSP00000327. So this is a short time later 11 and, scrolling down again, is this usual for there to 12 have been this much correspondence between yourself and 13 the NFSP at this time? 14 A. It was quite appropriate. I can't remember the 15 frequency of how much we were in touch. I mean, we 16 spoke a lot by telephone as well as in person. So it 17 wasn't out the ordinary, but it's quite appropriate to 18 keep people informed of what's happening. 19 Q. Picking it up, it says: 20 "Since writing to you earlier today we have held 21 our meeting with ICL Pathway to review readiness to 22 begin the pilot on the new software release, CSR+. 23 "We have taken the decision to proceed with the 24 date centre migration next weekend subject to 25 confirmation from ICL that they have robust plans in 29 1 place to fix an intermittent problem around preservation 2 of data when swapping faulty kit out on some 3 multi-position counter terminals, and no new issues 4 emerging in remaining tests next week." 5 Surely it's better to have those safeguards in 6 place first before deciding to continue with the 7 release; would you accept that? 8 A. Yes. 9 Q. Do you feel like this was or this symbolises really the 10 release being pushed through too quickly, or did you 11 feel that this was appropriate? 12 A. No, it wasn't. I mean, there were certain safeguards 13 there that we wanted to ensure before we agreed for it 14 to go ahead, and that's in effect what this is saying. 15 MS KENNEDY: Chair, now may be an appropriate time for a 16 short break. 17 SIR WYN WILLIAMS: Yes, that's fine. 18 MS KENNEDY: 11.00? 19 SIR WYN WILLIAMS: Yes, certainly. Thanks. 20 (10.44 am) 21 (A short break) 22 (11.00 am) 23 MS KENNEDY: Good morning, Chair. 24 Mr Grey, if we could pick up NFSP00000318, thank 25 you, this is a letter dated 25 August 2000 that you sent 30 1 to subpostmasters I think is that right? 2 A. I believe so, yes. 3 Q. Did you often write directly to subpostmasters? 4 A. No, no. 5 Q. Was the reason you were writing subpostmasters in this 6 instance because of the big changes that were going to 7 happen and the big requirements of them? 8 A. That's right. It was a very significant development, 9 and we needed everybody to be on board with it. 10 Q. If we scroll down that letter, it says: 11 "As you may be aware, we are shortly to undertake 12 the next Horizon software release known as CSR+. An 13 inherent change in this release is to make improvements 14 in cash remittances for the benefit of the business and 15 users. The enclosed training package is essential 16 reading to prepare you for these changes and explain the 17 link submission the logistic feeder service. 18 "As a subpostmaster or office manager, you must 19 complete the whole workbook in advance of the upgrade 20 being released. You will be advised of your upgrade 21 date during the three weeks prior to the event. Please 22 allow two hours for the workbook activity. Once your 23 office has been upgraded, the workbook contains 24 activities which can be undertaken in training mode to 25 consolidate your learning and you will need to allow 31 1 yourself time to practice these." 2 Looking down to the fourth paragraph: 3 "When training consolidation has taken place 4 please complete and return the enclosed free post 5 addressed response card to confirm that all training, 6 including training briefs 27 and 28 which you will 7 receive separately, have been undertaken by all 8 concerned in your office. This is a mandatory 9 requirement to confirm that all post offices are 10 prepared for this change. The completed card must be 11 returned within five working days of your upgrade." 12 So this is a significant change, as you have 13 already said. Did you feel like you were asking a lot 14 of subpostmasters to adapt to this changing computer 15 system? 16 A. No, we didn't think we were asking a lot of them, but it 17 was important that we actually had them properly 18 prepared for the change, and that's the significance of 19 this letter. 20 Q. Did you feel that the Post Office equipped 21 subpostmasters well for this big change? 22 A. Yes. I don't think there was any great feedback to the 23 contrary. 24 Q. How did you ascertain whether or not people felt 25 prepared for this change? 32 1 A. Really by feedback that we actually received by general 2 means, either through the NBSC Helpdesk or by feedback 3 on outlet visits and contacts with NFSP reps. 4 Q. So you didn't decide to conduct another research report 5 at this time? 6 A. We did about this point in time, because there was some 7 the further research done in the autumn of 2000. 8 Unfortunately I haven't been able to see that research 9 other than by referencing to other documents, but I'm 10 not sure that that research was done as a consequence of 11 the CSR+ release. I think it was probably more just 12 ongoing work to make sure we were on the right track. 13 Q. If we could turn forward to 6 September and it's 14 POL00104602 and if we look that bottom email, this is an 15 email from you to a group of people including Keith 16 Baines and it attaches an initial draft of the NRO close 17 down report. 18 If we look over the page to page 2, we can see 19 that this is your kind of draft report. What is this 20 report and how did it come about? 21 A. This is an essential part of ending a particular project 22 to make sure that there's a proper handover to enable 23 any incomplete work to be conducted by others, and to 24 make sure that the full requirements of the project have 25 actually been fulfilled. 33 1 Q. If we turn over to page 5, we can see what you have just 2 said reflected in the introduction: 3 "The completion of the national roll out of 4 Horizon gives us the opportunity to take stock of 5 achievements and experiences and provide a means of 6 transferring incomplete activity to other functions. 7 This process covers the work to wrap up the project, 8 primarily to prepare input to the project board to 9 obtain its confirmation that the project may close." 10 If we scroll down, Outputs, it says: 11 "The outputs from this paper will be a high-level 12 plan which will define the steps that the NRO project 13 board and management team must undertake to formally 14 close the project." 15 Under Project Closure, it says: 16 "To confirm that the project has delivered what 17 was expected, the NRO project board will be asked to 18 verify that first the Horizon implementation activity is 19 complete and meets needs of the business; second, the 20 satisfactory arrangements exist for the transfer of 21 residual responsibilities to other business units, all 22 project issues are closed or transferred to other 23 functions to follow up [and turning over the page] all 24 relevant project information is secured and archived or 25 handed on as applicable to permit any future audit of 34 1 the project's actions and performance; all involved or 2 interested parties are aware that the project is to be 3 closed and resources disbanded." 4 Scrolling down a bit further, it says: 5 "The project manager has responsibility for the 6 process and will maintain a regular dialogue with the 7 project board to ensure there will be no problems with 8 its confirmation of the project closure. 9 "The key criteria to be applied are: 10 "Have all the elements of the project initiation 11 document been delivered, subject to any changes that may 12 have been approved during the project life-cycle? 13 "Are any deviations from the project initiation 14 document addressed in the project close-down report? 15 "Is the project board still prepared to accept the 16 project closure? 17 "When appropriate, are any deviations reflected in 18 the follow-on action recommendations? 19 "Are the project board satisfied that any 20 outstanding project issues have been baton passed to 21 others to pursue? 22 "Have gaining business units formally agreed to 23 the transfer of residual responsibilities and signalled 24 their readiness to accept the work? 25 "Are the project resources and support services 35 1 not being transferred elsewhere no longer required? 2 "Are there any contractual implications when 3 decommissioning the project?" 4 So in your mind was this you setting everything up 5 so that it can be assessed whether or not the criteria 6 have been met by the project board? 7 A. Yes. 8 Q. Who were on the project board? Who would be evaluating 9 whether these things had been completed? 10 A. To be honest, that escapes me now. I just can't recall 11 that information. 12 Q. Would it have been someone around your level? Would it 13 have been a different team? 14 A. No, I suspect it was probably director level which was 15 one rung above me on the ladder. 16 Q. Did you feel at the time that those people would have 17 been qualified to make those calls? 18 A. Yes. 19 Q. Turning forward to 21 September 2000, NFSP00000299, this 20 is another letter from you to the NFSP. If we look at 21 the first paragraph it says: 22 "Thank you for your letter of 15 September about 23 Horizon installation activity during December. Whilst 24 I can fully appreciate the sensitivity of this issue 25 I was surprised by the tone given the discussions we 36 1 have had in recent weeks." 2 Was this a time where relationship with the NFSP 3 was fraught or difficult? 4 A. No, I don't think so. I can't remember what the letter 5 said on 15 September but, no, I would never describe the 6 situation with the Federation as fraught. We used to 7 speak our minds, but we were always very positive in the 8 way that we tackled issues. 9 Q. Turning then to 5 October 2000, if we could turn up 10 NFSP00000289, this is an update that you provided to 11 Mr Baker. If we can scroll down, looking at national 12 roll out progress and if we can look that training: 13 "Training over 60,000 people has not been without 14 its problems. Course scheduling and occupancy levels 15 have been major issues with ICL Pathway over the recent 16 months. Happily their administration of user training 17 events is now within acceptable bounds, but we now find 18 ourselves in the position of training fewer people yet 19 needing more courses than the contract provides for. To 20 address the gap we have developed a number of 21 initiatives including allocating seven delegates to some 22 courses, redistributing training costs including making 23 more prudent use of user awareness events and extending 24 the training window to 10 days before installation. The 25 extension of the distance limit to 25 miles will also 37 1 have a beneficial effect." 2 Did you feel like you had to do the impossible or 3 do a very difficult task in carrying out this training? 4 A. In this particular aspect of the training, yes, because 5 we're getting towards the end of the project, having 6 completed the first sweep over the country, and we were 7 now faced with a situation where the problems with 8 scheduling the events in the past had caught up with us. 9 So we had to take some actions which we didn't want to 10 take but had to take to get through the project within 11 the terms of the agreement with ICL. 12 Q. What was morale like in your team at that time? 13 A. The morale in the team was always good. It was a good 14 team. They were a cheerful bunch, they were very much 15 a can-do bunch, and we just got on and did it. 16 Q. Turning over to page 2, scrolling down, under Live 17 Environment: 18 "Helpdesk Performance -- although there have been 19 some blips as a result of recent incidents, such as the 20 instruction of the Inland Revenue working families tax 21 credit facility, there has been an improvement on both 22 Network Business Support Centre [the NBSC] and Horizon 23 System Helpdesk performance. The introduction of 24 interactive voice response on the HSH on the two busiest 25 days of the week, namely Wednesday and Thursday, was 38 1 well received though it did impair the percentage calls 2 answered under 20 seconds as a consequence of the 3 duration of the recorded message. This facility was 4 introduced as a temporary expedient and is to be 5 withdrawn next week now that all HSH operators are fully 6 effective. Average number of weekly calls per outlet to 7 HSH is currently 1.17 compared to 1.4 for the NBSC, 8 which in itself is 5 per cent lower than the regional 9 helpline internal calls. NBSC are now achieving almost 10 all their call handling performance in all dimensions; 11 the latest time to answer performance is 8 seconds with 12 over 75 per cent of calls now being resolved by the 13 initial call handler." 14 At this stage did you feel like Helpdesk 15 performance was improving or had improved, and were you 16 happy with it? 17 A. It had improved. We were always watching the 18 performance of the Horizon System Helpdesk particularly, 19 because that had been a problem for some time, and we 20 needed to make sure that it didn't deteriorate. By 21 comparison, the NBSC at 8 seconds to answer calls was 22 very much gold standard by comparison with call centres 23 these days. 24 Q. Turning on to page 4, please, it says "Staff and 25 Subpostmaster Feedback": 39 1 "The latest research across a sample of staff and 2 subpostmasters some two or three months after migration 3 to Horizon indicates a better feel-good factor across 4 the network. 94 per cent find the system easy to use, 5 80 per cent say user training is good and 90 per cent 6 find balancing easier. Results show a significant 7 positive movement on live trial and encouraging 8 improvements on previous research in December 1999. Not 9 surprisingly, subpostmasters find transactions easier 10 than balancing to master. After an intense training 11 course they need time for familiarisation with the 12 system in their own environment. Other feedback from 13 outlet visits, Helpdesk calls and other communications 14 (eg the subpostmaster journal) echoes this feedback." 15 So at this time were you happy with the way that 16 that feedback had tracked and that it had become more 17 positive? 18 A. Indeed. I mean, this sort of vindicated the actions we 19 took at the beginning of that year to get results like 20 this and, in fairness, when you look at those kind of 21 percentages, I mean, there would be many retailers these 22 days, if that was about their products, they'd be very 23 satisfied with the situation. 24 Q. Do you feel that issues with training might have masked 25 data integrity issues? People thought that training 40 1 issues or Helpdesk problems were the cause of the 2 problem but, in fact, with hindsight it may have been 3 data integrity? 4 A. I don't know. I don't feel I'm qualified to answer that 5 particular question. 6 Q. Is it fair to say at this time in October 2000 you were 7 assuming that the system wasn't causing balancing 8 problems? 9 A. I wasn't aware of any balancing problems that were 10 significant and that would cause any particular problem 11 to the project, to the subpostmasters or staff who were 12 involved. 13 Q. If we could turn up the next document -- 14 SIR WYN WILLIAMS: Sorry, Ms Kennedy, just so that I'm not 15 thinking a false point, could you go back a page, 16 please, on that document. 17 It's at the bottom of that page 3. No, sorry, 18 I seem to have -- can you start at the ... yes, that's 19 it. "Cash accounts". Do you see that paragraph which 20 appears to be highlighted? What I wondered was this. 21 If you read that paragraph to yourself, Mr Grey, you'll 22 see the last sentence in particular: 23 "The level of errors on Horizon continues to fall 24 but is still not returned to pre-Horizon levels", and 25 that relates to cash accounts. 41 1 I wondered if you could explain to me what that 2 relates to so that I don't have any misunderstanding of 3 it. 4 A. Indeed. Are we talking specifically about the last 5 sentence, or would you like an explanation about the -- 6 SIR WYN WILLIAMS: The whole paragraph, please, but 7 obviously in the context of that sentence. 8 A. Right. In terms of the unclaimed payments on charge and 9 receipts, these are discrepancies which have been 10 identified and are awaiting error notices. 11 SIR WYN WILLIAMS: Yes. 12 A. And there were fewer of these in the automated system, 13 as one would expect. In fact, that's a benefit of 14 automation. In terms of the authorised shortages, these 15 would be amounts which were held in suspense pending 16 further investigation, probably by the transaction 17 processing team in Chesterfield, when the cash accounts 18 were received by them and they were able to match the 19 cash account with the associated documents and correct 20 any problems. 21 Now, it's quite conceivable that there will be 22 more or those, because the retail network managers were 23 giving subpostmasters the benefit of the doubt and 24 putting the items into suspense to give the opportunity 25 for these to be properly investigated. 42 1 SIR WYN WILLIAMS: Right. 2 A. In terms of the level of errors, I'm not quite clear 3 what I was referring to there, but clearly I've had some 4 information where I've actually compared it with what 5 happened before. 6 SIR WYN WILLIAMS: I mean, an interpretation of it is simply 7 that there are user errors on Horizon which are greater 8 than the user errors had been prior to Horizon. But 9 it's also possible that that is an acknowledgement that 10 there are system errors on Horizon, and I wondered if 11 you could help me with that. Then, secondly, the second 12 part of the sentence: 13 "An analysis of root causes has led to a number of 14 remedial actions being taken." 15 I mean, what were the root causes, and what were 16 the remedial actions? 17 A. I cannot tell you what they are at this point in time. 18 SIR WYN WILLIAMS: All right. 19 A. But Business Service Management had the responsibility 20 for actually identifying the issues, analysing them and 21 trying to put things right where there was an identified 22 cause. I don't think the level of errors is anything to 23 worry about unduly. I think that is just a reflection 24 of the fact that there were problems in the system as 25 people got to grips with it. I was not aware of any 43 1 system errors, so I don't think that is any undue 2 concern at that particular point in time. 3 SIR WYN WILLIAMS: All right. Thank you. Sorry, 4 Ms Kennedy. I just wanted to be as clear as I could be 5 about what that paragraph meant. 6 MS KENNEDY: Thank you, Chair. 7 If we could turn up the next document then, 8 POL00104482, and this is from April 2001. This is 9 a report that you wrote; is that right? 10 A. Yes. 11 Q. It's called the Project Implementation Review Horizon 12 National Roll Out. What was the purpose of writing this 13 report? 14 A. This was really to prepare for the close down of the 15 project, which was a few months away when this was done, 16 and this was a draft document to prepare us for that 17 eventuality. 18 Q. How did you feel about the project at the time of 19 writing this report? Did you think it had been 20 a success? 21 A. I did, yes. I know it had been accompanied by various 22 problems, but all in all I think the achievement of 23 everybody involved, including subpostmasters, was one 24 that reflected with credit on them. 25 Q. In this report you go through a number of issues or 44 1 themes to do with the system. I wonder if we could turn 2 up page 2, please, and scroll down and down again, 3 please. 4 So at 2.2: 5 "Satisfactory roll out of Horizon to all outlets 6 taking remedial action to secure business performance by 7 initiating or developing policies/frameworks 8 appropriate." 9 So what was this about? What was this heading 10 analysing; do you remember? 11 A. Not specifically. No, this, I think, was just to make 12 sure we could maintain the business having rolled out 13 Horizon to the outlets. 14 Q. If we go over the page and we look at the first full 15 bullet point, it says: 16 "The absence of a coherent and robust outlet in 17 product reference system was evident at various times 18 during the project." 19 Do you remember what that means or meant? 20 A. Yes, that's related to the nature of the outlets. Each 21 sub-post office was quite unique. There were no or very 22 rarely two sub-post offices that were identical and what 23 that was relating to was some kind registry, if you 24 like, or what each office looked like and what 25 facilities it had. 45 1 Q. If we could turn over to page 5, please, and scroll 2 down, please. You have got "Performance Operational", 3 and then scrolling down again, please, "Performance 4 Technical". So were those divided in between the 5 operation of the system on the ground and then 6 technically the detail that's kind of in the back office 7 or on the computer system itself? 8 A. Sorry, I'm not clear. 9 Q. What is the difference between performance operational 10 and performance technical? 11 A. Right. Well, operational would be what actually 12 happened out in the field. Technical would be the 13 system and the way it was put together and rolled out. 14 Q. If we look at Performance Technical, it says: 15 "Technical oversight and validation of ICL Pathway 16 activities was almost non-existent compared with the 17 preceding live trial and development phase. Although 18 this was not really a problem, it is an area that should 19 not be overlooked either in the Horizon maintenance 20 phase or in future projects." 21 What did you mean by that? 22 A. I think that relates to the fact that it had changed 23 from being a sort of a three-party project to 24 a two-party project, and it became a much more 25 commercial contract arrangement, and there wasn't the 46 1 same kind of sharing that actually went on when it was 2 a combined project. 3 Q. Did you feel it would have been helpful if things had 4 stayed the way that they were; it was more co-operative? 5 A. No, I'm not suggesting it should have carried on as they 6 were, but I think there was certainly scope for improved 7 co-operation between ourselves and Pathway. The 8 relationship with ICL was constructive and cordial, but 9 there were times when we felt that we weren't treated as 10 a valued customer and being given all the information 11 that we felt we had a right to know about. 12 Q. What information was that that you felt you didn't have? 13 A. Well, it related to particular problems. There were 14 times when we felt we might be being fobbed off, that 15 there was -- either for cultural, commercial or other 16 reasons, we weren't being told all the information that 17 we should really have been given. 18 Q. If we turn on to page 6, please, and scrolling down we 19 have "Recommendations", "Supplier Issues" and, looking 20 at the first bullet point, it says: 21 "The project understandably for its size and 22 nature had a heavy contractual overlay. Despite best 23 endeavours to establish open, constructive, 24 customer-focused and forward-looking relationships with 25 ICL Pathway directors, we did not succeed in mirroring 47 1 the relationships which existed at working level. 2 Consequently, consideration ought to be given in similar 3 supplier-dominated projects in future as to how we can 4 secure commercial benefit via a more creative, 5 constructive and less restrained joint working or 6 partnership arrangement at all levels so that both 7 parties secure a win-win position." 8 The second bullet point: 9 "We should never again put ourselves in the 10 position of dependence on either a sole supplier (or, 11 indeed, supplier-dominated project progress information) 12 without first establishing a defined and adequate 13 contingency. At the outset we should assure customer 14 pre-eminence with any future supplier who must commit to 15 identify, agree and deliver to our requirements, 16 including detailed performance metrics and integrated 17 reporting structures. Furthermore, any future supplier 18 must empower their local field teams to mirror the 19 responsibilities we invest in our people." 20 So what are you saying there? 21 A. Effectively we're saying that the customer has got to 22 come first, and we've got to make sure that any 23 contractual arrangement we have with any future supplier 24 has got to recognise that, and we build the project 25 around it. 48 1 Q. What about the first line: 2 "We should never again put ourselves in the 3 position of dependence on either a sole supplier ..." 4 So what's the learning point from dependence on 5 a sole supplier? 6 A. Well, in a sense, because of history on this particular 7 project we were left with effectively no alternative but 8 to go with ICL, and maybe what should have been 9 a preferable route is to have competitive tendering. 10 Q. Could you turn over to page 8 of that document and 11 scroll down, please. Under "Training", it says: 12 "All training courses and training content to go 13 undergo more in-depth development and quality checks 14 prior to delivery to ensure user comfort. Training 15 should be viewed as a process rather than event and 16 ensure it caters for different learning pace, styles and 17 requirements. A one-size-fits-all approach is not 18 always appropriate, especially if an established 19 learning environment does not exist." 20 Were you disappointed with the level of training 21 when you first came on board versus by the end of this, 22 after all your efforts? 23 A. I think perhaps it hadn't been given the attention that 24 perhaps it had deserved but in fairness there was a lot 25 of other issues going on at the same point in time. 49 1 But, in fairness, we rescued the situation and, whilst 2 there might have been some hiccups along the way, 3 I think we got through pretty well despite. 4 Q. Even in light of these problems that you flagged in the 5 report, were you optimistic about the continued 6 involvement of ICL going forward? 7 A. I wasn't particularly optimistic. I mean, it was 8 something that we needed to keep our eye on. Once I got 9 to Business Service Management, it was fairly clear we 10 had to monitor the Horizon System Helpdesk performance 11 on an ongoing basis, because that was still an issue. 12 So we couldn't take our eye off the ball at all. 13 Q. Moving forward to 26 November, if we could pull up 14 FUJ00119979. These are the notes of a Horizon Service 15 Review Forum, and we can see there that you were the 16 Chair of this. What was the Horizon Service Review 17 Forum? 18 A. Well, as it says there, in the Purpose towards the 19 bottom of that page, it was to discuss with ICL how they 20 were meeting their performance objectives. 21 Q. How useful did you find this as a forum? 22 A. To be honest, I'd forgotten we ever had these, but 23 clearly it was a means of actually debating face-to-face 24 the real issues of the day. 25 Q. How often did these take place; do you remember? 50 1 A. I think these took place on a monthly basis, though I've 2 a feeling about this point in time it actually reduced 3 to two-monthly. 4 Q. If we turn on to page 2, we can see the notes and we can 5 have the action -- we see the action point number the 6 details, date to be completed by, the owner, the actions 7 taken and the action points status. So at these 8 meetings did someone raise an issue, someone made a note 9 of it, and then it was tracked? Is that how that took 10 place? 11 A. Yes. 12 Q. How were the action points carried forward? 13 A. Well, they were tracked at each meeting. So it was 14 actually being work that was being taken away from the 15 meeting and done offline, so to speak, and the meeting 16 maintained an oversight to make sure that progress was 17 being maintained towards resolution. 18 Q. Did you find that relationships were good in this forum 19 and that it was useful? 20 A. Yes, I think again there was the issues about the not 21 always sharing information with us but, yes, they were 22 generally useful and, in fairness, I think we got a fair 23 bit done. 24 There is an example in another document that I've 25 seen which relates to the fact that we were working 51 1 together to have a better service for the post offices 2 by a closer arrangement between the Horizon System 3 Helpdesk and the NBSC. 4 Q. Turning forward to 1 December 2001, if we could turn up 5 FUJ00120085, this is an ICL document. It's a customer 6 satisfaction scorecard. So you wouldn't have seen this 7 at the time, would you? 8 A. Well, I think I must have done because down the bottom 9 there it's got "Signed by head of BSM", or there's space 10 for it anyhow, and I suspect this was something that was 11 actually being pioneered. 12 Q. So do you remember receiving these on a regular basis 13 and signing them? 14 A. I don't remember doing so. I don't know whether this 15 was a prototype which never took off or whether it was 16 something that did in fact become a regular occurrence. 17 I can't recall honestly. 18 Q. Turning over to the second page, it says: 19 "Scorecard quarter ending November 2001", and it 20 says: 21 "Don Grey: difficult and thought-provoking 22 exercise. POL comment sometimes reflects ICL Pathway in 23 general." 24 Do you have any idea what this is about or do you 25 remember saying this? How would this be recorded? 52 1 A. Well, this is relating to the score card we've just been 2 looking at, and this is what makes me think it might 3 have been a prototype that were actually being suggested 4 by ICL as a means of actually doing on a regular basis. 5 But whether it ever took off regularly, I don't know. 6 Q. Did you find it a difficult and thought-provoking 7 exercise? 8 A. I must have done to say that. 9 Q. If we could then turn up FUJ00080421, this is from 10 25 September 2002, and this is an agreement about the 11 interaction between the NBSC and the Horizon System 12 Helpdesk. Do you remember how well these two helpline 13 entities were working together at this time? 14 A. Well, I think there is a sense of operating in different 15 silos initially, and this was an attempt to really bring 16 together and to try and make them seamless as far as the 17 post offices were concerned. 18 Q. So this was produced in recognition of a problem about 19 the fact that two were working in silos and there needed 20 to be greater cooperation? 21 A. Yes, it was more a recognition of an improvement 22 opportunity rather than a problem, I think. 23 Q. If we turn over to page 7, for example, and scrolling 24 down and down again, please, we can see that the scope 25 of the document is set out: 53 1 "How the NBSC and HSH will provide a seamless 2 incident management service to Post Office and agreed 3 POL and Fujitsu Services Pathway Support Groups." 4 Looking down that bottom of the page, it says: 5 "The document defines exceptional event as an 6 event that may cause a 75 per cent increase in call 7 volume and/or is likely to impact the operation of the 8 call management process. Under these circumstances, 9 direct communication will take place between HSH and 10 NBSC." 11 Was that the real concern, that both parties 12 should be sharing information on when something is 13 likely to increase call volumes? 14 A. That was one of the issues it was trying to address. 15 The other one was to make sure that people weren't being 16 passed between call centres unnecessarily. 17 Q. Was that the feedback that you were receiving at this 18 time, that people were being passed between them? 19 A. No, no, no, but we identified it as the way that we 20 could actually provide a better service together. 21 Q. If we could turn up page 14, please, we have some 22 diagrams, if we can scroll down. This is the interface 23 between NBSC and HSH. Were these provided to helpline 24 operatives? 25 A. To be honest, I don't know where these ended up. They 54 1 were part of this particular document, but I would have 2 expected that they would have been provided to call 3 handlers in a much more understandable way than this 4 document. 5 Q. By the time you left, how well did you feel these two 6 systems operated co-operating with one another? 7 A. Much better but still scope for improvement. 8 Q. What did you think that could have been improved? 9 A. There were things that could be improved. I can't 10 remember what they were specifically, but we could never 11 take our foot off the pedal because we needed to make 12 sure that the performance didn't falter. 13 Q. Mr Grey, those are all the questions that I had for you. 14 Chair, do you have any questions at this stage? 15 SIR WYN WILLIAMS: No, thank you very much, no. 16 MS KENNEDY: I think Mr Jacobs has some questions, as does 17 Ms Patrick and Mr Henry, starting with Mr Jacobs. 18 MR JACOBS: Thank you, sir. Can I just confirm that you can 19 hear me. 20 SIR WYN WILLIAMS: Yes, I can, yes. 21 Questioned by MR JACOBS 22 Q. Thank you. Mr Grey, good morning. I want to ask you 23 some questions on behalf of the 156 subpostmasters, 24 mistresses, assistants and managers that I represent 25 instructed by Howe+Co and, in particular, some points 55 1 you make in your statement about the Horizon Helpdesk 2 and the user manual and the Christmas Horizon research 3 Report. 4 So could we perhaps go to paragraph 4(e) of your 5 statement which deals with the Horizon Helpdesk and 6 that's at page 7 of 26, WITN05220100. 7 Just waiting for it on the screen there. So you 8 can see that in that statement you say at the end in 9 relation to the Helpdesk: 10 "The time to answer and the quality of responses 11 was regularly monitored and improvements were made when 12 required." 13 Do you accept that's what you say about how the 14 Post Office dealt with the Helpdesk? 15 A. Yes. 16 Q. Now, in your evidence this morning you said, "It was 17 clear that we had to monitor the Horizon System Helpdesk 18 performance as an ongoing issue, so we couldn't take our 19 eye off the ball at all." Is that right? 20 A. Mm-hm. 21 Q. Did you listen to the evidence that was given by 22 subpostmasters in Phase 1 of this Inquiry from February 23 to May 2022? 24 A. No, I haven't. 25 Q. I wanted to put to you some of what the subpostmasters 56 1 whose evidence was uncontested said about the Helpdesk 2 in this Inquiry. We've looked at 102 of our clients' 3 statements. 50 of them gave evidence live, the rest 4 were read into the record. 88 of our clients gave 5 evidence that Horizon staff were incompetent. 6 Is that something that you knew about, that that 7 was the general view about Helpdesk staff? 8 A. No, not at all. I think we need to distinguish between 9 the two Helpdesks. The Network Business Support Centre 10 I would not describe as incompetent, nor would I do so 11 for the Horizon System Helpdesk. There were resourcing 12 issues and scheduling issues at the Horizon System 13 Helpdesk at certain points in time, and they were 14 addressed after we made some challenges to get them to 15 improve their service. 16 At what point in time are we actually talking 17 about with those statements a matter of interest? 18 Q. Throughout the course of the scandal, from rollout 19 through to the litigation, a wide variety of time 20 ranges. 21 A. Right. Well, I'm talking about the time I was actually 22 with the project and with the Business Service 23 Management which ended in early 2003. 24 Q. Yes, of course, and of course -- 25 A. I can't say. 57 1 Q. You can only give evidence from what you experienced. 2 So, in the time that you were involved, our clients, 18 3 of them say that, when they eventually got through to 4 the helpline, the people who were supposed to be helping 5 them were just reading from a script. Is that something 6 that you are aware of, a complaint that you received? 7 A. It's not a complaint. I mean, call handlers do work 8 from scripts, and that's very important to make sure 9 that there's consistency of message. 10 Q. Did you see the scripts that the call handlers were 11 working from? 12 A. I must have seen them at some point in time, but 13 I wasn't involved in vetting them and making sure they 14 were fit for purpose. That was the responsibility of 15 others in the team. 16 Q. Can you describe what the scripts looked like, what the 17 format was, from the ones that you saw? 18 A. Not from memory I can't, no. 19 Q. One of the issues that subpostmasters have raised, 39 of 20 our clients say they were told, expressly told, that 21 they were the only person experiencing problems with the 22 Horizon System. Now, that's a theme that emerged from 23 the evidence, and we say it can't be a coincidence. 24 Are you aware that there was anything to that 25 effect within the scripts themselves? 58 1 A. Not that I am aware of, and I wouldn't be too happy 2 about that message actually being given out. Do we know 3 which Helpdesk we're talking about? 4 Q. This is the Horizon Helpdesk. 5 A. Right, this is the ICL one? 6 Q. Yes. 7 A. Right. 8 Q. 36 of our clients were told, "You have to pay the 9 shortfall because under your contract you are bound to 10 do so." Is that advice that you recall being given? 11 A. Well, subpostmasters had the responsibility for making 12 good losses -- that was part of the contract -- and it's 13 quite conceivable it was something to that effect in the 14 scripts but, as I say, I can't recall. 15 Q. If the Inquiry wanted to -- and this is a fishing 16 expedition, sir, and I apologise for that -- if the 17 Inquiry wanted to find these scripts, do you know who 18 might have them or where they might be located? 19 A. I don't know where they would be now, but in my day they 20 would be in each of the respective Helpdesks. 21 Q. You see, our clients say, all of them say, that the 22 Helpdesk service was woeful and that it did not improve. 23 Do you accept that there is a significant disconnect 24 between the uncontested evidence of subpostmasters in 25 this Inquiry, and your evidence that the Post Office 59 1 monitored it, made sure that there were improvements, 2 and kept their eye on the ball? 3 A. I don't accept there is that disconnect. I mean, 4 clearly there are people who would not be too happy with 5 the service that may have been provided at various 6 stages in the project, even in basic business-as-usual 7 operations. It's unfortunate, but those are issues that 8 need to be addressed specifically at the time. 9 Q. I'm going to move on in a minute, but I just want to 10 take you to your statement again and what you say at 11 paragraph 4. 12 SIR WYN WILLIAMS: You are very quiet now, Mr Jacobs. Can 13 you address that, please. 14 MR JACOBS: Yes, I think that's a bit closer. 15 You say at paragraph 4(e): 16 "The time to answer and the quality of responses 17 was regularly monitored and improvements were made where 18 required." 19 In hindsight, in relation to the evidence that 20 this Inquiry has heard and accepted, do you accept that 21 that statement is not correct? 22 A. No, I don't accept it's incorrect. We did, in fact, 23 monitor performance of both Helpdesks and we did make 24 improvements. 25 Q. Well, we'll move on. 60 1 In relation to the user guide or helpbook, you say 2 that the Christmas Research Report said that just over 3 half, that's 55 per cent, of users found this guide 4 helpful. Not one of our clients -- 5 A. Are we talking about the Horizon user guide here? 6 Q. This is the Horizon user guide or the handbook that you 7 are referring to at 4(f) in your statement: 8 "All post offices were issued practical user 9 handbook, the Horizon Guide, to explain in some detail 10 Horizon operations and assist their move to the new 11 system." 12 It's that guide I'm referring to. 13 A. Right. 14 Q. Not one of our clients has said that this guidebook was 15 of any use to them whatsoever. What do you have to say 16 about that? 17 A. Well, there were a number who would prefer to phone the 18 Helpdesk rather than read the guide and that, I think, 19 is also covered in the research. 20 Q. Do you agree with the benefit of hindsight that the 21 Horizon Christmas Research Report, even though it was 22 relatively negative feedback, nevertheless overstated 23 the usefulness of this guide to subpostmasters when the 24 problems started to materialise? 25 A. No, and I don't accept that the research report was 61 1 negative. There was some positive information in there 2 as well, some very really improvement opportunities, but 3 it certainly wasn't negative in total. 4 Q. Mr Grey, a large number of my clients and a very large 5 number of subpostmasters were very badly let down by the 6 Helpdesk. Do you have anything that you would like to 7 say to them? 8 A. Well, all I can say is I'm sorry to hear that and, had 9 I known that at the time that I was in charge of the 10 Helpdesks, I would have certainly taken that forward on 11 their behalf. 12 Q. Finally, a significant number of subpostmasters have 13 said that they were advised by Helpdesk that they were 14 the only ones experiencing problems with the Horizon 15 System. Do you have anything to say to that? 16 A. Again that is not a very helpful comment to make and, 17 had I known that at the time, then that again would have 18 received my attention. 19 MR JACOBS: I'm just going to ask if there are any more 20 questions that I have to ask you. No, that's it, thank 21 you. 22 Thank you, sir. 23 MS KENNEDY: Ms Patrick? 24 MS PATRICK: Thank you. 25 /// 62 1 Questioned by MS PATRICK 2 Q. Mr Grey, my name's Angela Patrick. Can you see and hear 3 me? 4 A. I can indeed, yes. 5 Q. I act for a number of subpostmasters with Mr Moloney KC 6 instructed by Hudgells, and our clients, over 60 of 7 them, were convicted but have since had their 8 convictions quashed. We would like to ask you a few 9 questions about one issue, and I hope you will be glad 10 to hear it's not about training, and it's not about the 11 Helpdesk. 12 Can we look again at the letter that you have been 13 taken to this morning that was sent to you in May 2000. 14 You have seen a lot of documents. I will bring it up so 15 that you can see it. It's NFSP00000332. If you 16 remember, this was the letter about non-polling. Can 17 you see it now? 18 A. I can, yes. 19 Q. That page is pretty familiar to you because Ms Kennedy 20 has taken you through some of this already and, if you 21 remember, it was about non-polling, which I think you 22 recalled was a significant problem. 23 A. It was a problem -- significant perhaps might be going 24 too far but at particular points in time it may have 25 been. 63 1 Q. I want to look at the second page. If we can turn over, 2 and specifically I want to look at the second paragraph 3 if that could be highlighted for you. If we see there: 4 "After the meeting this afternoon, I received 5 a phone call from Colin Baker and he tipped me off that 6 the DTI representative at the conference had reported 7 back the problems with polling, and that Alan Johnson, 8 Minister for Competitiveness at the DTI (and responsible 9 for the Post Office) has a asked for a copy of 10 transcript of this part of the conference." 11 Now, you said this morning that you were being 12 copied in on a lot of things that really wouldn't 13 specifically require your attention. Would this, the 14 minister responsible for the Post Office seemingly 15 expressing an interest in or a concern about 16 non-polling, be a significant issue? 17 A. Yes, this coincided with me being at the conference as 18 well and, as I recall, this actually happened while 19 I was either at the conference or in transit from it. 20 Q. This was you essentially being alerted to the minister 21 being aware of these problems, wasn't it? 22 A. Yes, indeed. 23 Q. It was really something you ought to have been aware of, 24 wasn't it? 25 A. Yes, indeed, and I was in fact copied in on that 64 1 correspondence, but what they had actually initiated was 2 an enquiry in my absence to actually identify what had 3 been going on. 4 Q. Can you remember what the Post Office Horizon team did 5 with this information and what happened next? 6 A. I think, if you scroll on in that document or associated 7 document with that, I think there was some indication of 8 what actually happened, that someone had picked this one 9 up and was actually running with it. 10 Q. I think we can see it is -- "Can you go back to Colin 11 and reassure him", and it has a number of bullet points 12 there, but none of them appear to relate to the 13 minister. 14 Do you know if you contacted the minister or his 15 team? 16 A. I didn't contact the minister or his team, no, no. 17 I don't know who had that responsibility, but I wasn't 18 the only one that was copied in on this letter. 19 Q. Do you know if anybody else in your team may have spoken 20 to him or his team? 21 A. I doubt it but it is possible. Something like this 22 would normally be handled by the public relations 23 people, I suspect. 24 Q. Who was above you in the management line between you and 25 the board at this time? 65 1 A. Well, David Smith was my boss. He was director of 2 automation and he was actually on the board. 3 Q. I think Stuart Sweetman told us he was director at POCL 4 until November 2001. Is that right? 5 A. Stuart himself, you mean? 6 Q. Stuart Sweetman. 7 A. Yes, Stuart Sweetman was the managing director, as I 8 understand it -- I think was his title. 9 Q. You've said this morning that you were aware of 10 Mr Johnson giving evidence to the Inquiry. Did you 11 listen to his evidence or did you read it? 12 A. No, I listened to it. 13 Q. Okay. I think, just to refresh your memory, his 14 evidence put briefly was that ministers were really 15 looking to the future for Horizon rather than the 16 technical problems, and he said in his statement: 17 "No-one was flagging up major concerns. 18 Everyone's attention was on the new work that Horizon 19 could attract." 20 The Inquiry's seen some examples of is. I'll 21 bring it up just in case you haven't seen it. We've had 22 it this morning, NFSP0000436, and if we look at the 23 bottom of page 2 in that document, it's the report of 24 the conference that we've been talking about. We can 25 see that there was an address by the minister. 66 1 A. Yes. 2 Q. We don't need to look at it all. He talks about his 3 long connection with the Post Office, his admiration for 4 people working for the Post Office, and he describes the 5 institution as "a Methuselah of the public sector". We 6 don't need to look at it all -- the Inquiry's seen the 7 evidence before -- unless you need to have some of it. 8 On page 5 he turns to Horizon. I'll paraphrase. 9 He talks about the Government's decision to get Horizon 10 back on track, ACT being inevitable, and opportunities 11 for the Post Office in Network Banking and the universal 12 bank. He ends on the Government's vision, and he talks 13 about the promise of the universal bank, and banks being 14 attracted by the incentive of the Horizon automation 15 platform. 16 Was that your recollection that ministers, Fujitsu 17 and the Post Office were all at this time all focused 18 first on the opportunities for Horizon? 19 A. That was the bigger picture, but on the ground we were 20 very much focused on making the project work. 21 Q. Yes. For those opportunities to work, first Horizon had 22 to work, didn't it? 23 A. Indeed. 24 MS PATRICK: Thank you. I don't have any other questions 25 for you, Mr Grey. 67 1 MS KENNEDY: Mr Henry? 2 Questioned by MR HENRY 3 MR HENRY: Hello, Mr Grey. Can you hear, sir? 4 A. I can. 5 Q. Good. You've already been shown today, so there's no 6 need for it to be put up on the screen, NFSP00000287. 7 I suggest that it's apparent from that document that you 8 are trying to drill down and investigate glitches, and 9 you were taken to that document by Ms Kennedy. 10 But you, of course, were the national roll out 11 manager appointed in January 2000 but, from July 2001, 12 you moved into the BSM function, didn't you? 13 A. Yes. 14 Q. Then of course you retired in March 2003. 15 A. Mm-hm. 16 Q. Correct? 17 A. Yes. 18 Q. So what I want to sort of try and explore with you is 19 perhaps a change in culture after you left because I've 20 been given permission to ask you about events that 21 occurred in 2005. Do you follow? 22 A. Yes. 23 Q. Now, you say at various points in your statement -- and 24 I'm not going to go to them because you have adopted 25 it -- but just for your benefit, sir, and for the 68 1 Chair's benefit, your paragraph 10(d) at page 20 of 26 2 that -- and I'm gisting this -- BSM would try to resolve 3 issues with root-cause analysis and transparency, good 4 communication, et cetera. You agree that's what you 5 said? 6 A. Yes. 7 Q. Paragraph 11(a), page 21, that bugs, errors and defects 8 they weren't hidden, they were deal with candour and 9 openness, correct? 10 A. (The witness nodded) 11 Q. Then paragraph 13, this is about error reporting, 12 paragraphs 23 to 26, error reporting, essentially there 13 was an open-business culture that people were encouraged 14 to report errors, and errors weren't being suppressed? 15 A. That's right. 16 Q. Now, sir, have you read -- and no criticism if you have 17 not -- any of the judgments of Mr Justice Fraser such as 18 the common issues judgment or the Horizon IT judgment? 19 A. No, I haven't. 20 Q. You haven't. Did it ever come to your attention, 21 directly or indirectly, while you were at the 22 Post Office that subpostmasters were not being told 23 about known errors in the Horizon IT System? 24 A. No. But there was no widespread arrangement to tell 25 subpostmasters but every problem. Where it was 69 1 important to them, we would actually communicate that to 2 them, but there were times when many of these, if you 3 like, were transparent and not apparent at the outlet 4 level where they were not communicated. 5 Q. Where did this no-need-to-know or need-to-know culture 6 originate because it follows, doesn't it, that somebody 7 is making a judgment about what the end user needs to 8 know about apparent errors in the system? 9 A. Where there was any effect on the users, they were 10 advised about the situation. If it didn't affect the 11 user, there was no need to know, because there was lots 12 going on in the background about trying to improve 13 issues between ourselves and ICL which had no impact on 14 the local user in terms of them knowing about any 15 potential problems. 16 Q. Upon whom were you relying for information about whether 17 this would, to use your words, impact or not affect the 18 end user? 19 A. We were relying on general feedback from the field, from 20 the Helpdesks and from anybody who may have been 21 involved in identifying what the root cause of that 22 particular problem was. There was a long time been 23 a requirement from subpostmasters, that they wanted 24 simpler and fewer messages, and what we didn't want to 25 do was burden them unnecessarily with communications 70 1 which had in our view, in the light of the information 2 we received, have any impact on them. 3 Q. This is very much, is it not, a sort of patriarchal or 4 patronising approach, in the sense that you are making 5 value judgments about what the children need to know, 6 aren't you? 7 A. No, I don't accept that. What we are doing is we are 8 exercising proper judgment and sharing with them as 9 appropriate. 10 Q. Can I just ask you to go back to your previous answer to 11 me, because you were saying you were relying on 12 information that was coming in from the field and also 13 the Helpdesk. Do you remember saying that just a short 14 while ago? So it follows that this information that it 15 doesn't need to be disseminated is coming from among the 16 field, in other words the branches, and also 17 subpostmasters calling the Helpdesk. How could that not 18 affect or potentially affect other postmasters? 19 A. It depends on the nature of the problem. You see, what 20 we're talking here is quite generally there could be 21 specific problems which were not apparent to 22 subpostmasters which we were actually dealing with 23 ourselves behind the scenes. 24 Q. That wouldn't of course arise from the field or the 25 Helpdesk, would it? 71 1 A. No, it wouldn't, but that was one of the other issues 2 that was relevant at the time. 3 Q. Just coming back to your immediate last answer, that's 4 precisely the problem, isn't it, that postmasters 5 weren't aware? We've seen evidence, for example, of the 6 Helpdesk where -- and this was put to Mr Terry Austin, 7 this document. Did you know Terry Austin? 8 A. I don't know him. I know the name. 9 Q. You know the name. Did you have an opportunity to look 10 at his evidence? 11 A. No. 12 Q. No. Well, fair enough. Where the Helpdesk is being 13 criticised by Mr Colin Baker because subpostmasters 14 don't know that these errors are occurring. A number of 15 things are just happening, as it were, without their 16 knowledge, and they are unsighted on these errors. 17 A. Which Helpdesk are we talking about, and what point in 18 time? 19 Q. Well, that was not the NBSC; that was the Horizon 20 services Helpdesk. 21 A. Right, which we had no direct responsibility for. 22 Q. Of course, but you, being, as it were, the correspondent 23 party, the client, Post Office POCL, you would obviously 24 be very concerned about that, wouldn't you, or ought to 25 have been? 72 1 A. Sure, if we were aware of it, yes. 2 Q. Can I just ask you this, and this is round about 2000 3 this document -- in fact, it is 2000 -- can I just ask 4 you, please, casting your mind back, surely that concern 5 must have been drawn to your attention then? 6 A. I wasn't aware of it. 7 Q. You, of course, were the Horizon National Roll Out 8 Project Manager and you weren't aware of it? 9 A. But without responsibility for the live environment at 10 that point in time. 11 Q. Why, as the National Roll Out Project Manager, did you 12 not have responsibility for the live environment? 13 A. Because that was the responsibility of others. I didn't 14 have responsibility for all the Horizon project, only 15 for actually the preparation, the training, the 16 installation of the system across the network. 17 Q. I see. So with this, as it were, fragmentation of 18 information, with these hermetically-sealed managerial 19 boxes, are you telling the Chair that you did not know 20 about this? 21 A. Yes. 22 Q. Do you think that that was an optimal way of rolling out 23 a system? 24 A. Well, it was for others to actually have that 25 responsibility, and it could well be that others knew 73 1 about it. Clearly, if it had had an impact on the 2 rollout, then I would have liked to have known about it. 3 Q. Can I ask you, please, were you aware -- and this is 4 both the Horizon Services Helpdesk, so therefore the 5 ICL, but also the NBSC -- were you aware that they were 6 advising SPMs to carry on balancing to produce cash 7 accounts in order to roll over; in other words, they 8 couldn't roll over unless they accepted figures that 9 they disputed? 10 A. I couldn't answer that question. I wasn't aware of it, 11 but I have become aware of it having seen some documents 12 and watched the various testimonies to the Inquiry. 13 Q. That would have been, in your view, utterly 14 unacceptable, would it not? 15 A. Well, there was a way of actually dealing with 16 situations like this. The amount would have been put 17 into suspense. The account would have been rolled over 18 and that would give more time for the amount in suspense 19 to be properly investigated and reasons found for it. 20 Q. Was the suspense function removed from the system during 21 your time at the Post Office or afterwards? 22 A. I think it must have been afterwards. I don't recall 23 that. 24 Q. I see. But anyway without, as it were, offering 25 a solution, I'm just asking you to comment on the 74 1 problem, and the problem was that they were quite 2 frequently being advised by both HSD and also NBSC to 3 accept and roll over notwithstanding the dispute. I ask 4 you again: that would be wholly irregular, wouldn't it? 5 A. It would seem to be so, but we had an arrangement where 6 that could have been properly accounted for, and that 7 was established and that should have been followed. 8 Q. So it was wholly irregular. 9 A. I wouldn't like to -- 10 Q. Why not? Why would you not like to say when you have 11 said that, first of all, that isn't the right advice 12 and, secondly, there was a potential solution, and that 13 advice that they were given completely ignored that, as 14 you have posited, that potential solution? 15 A. Well, I'm sure you are quite sincere in what you are 16 saying. I would want to find out more information 17 before I could make a statement like that. 18 Q. Okay. I'm now going to come to a matter that occurred 19 outside your remit, and I would be very grateful -- this 20 document, sir, has been notified to the Post Office, and 21 it's the evidence of Mr Kelly during the human impact 22 statements on 1 March 2022, and I would like to take it 23 from page 77 of that transcript -- page 77 of that 24 transcript, sir, from 1 March. 25 It was actually in the rule 10 question that we 75 1 were given permission to ask but, not to worry, I can 2 just go to the gist. Don't worry about it; I'll just go 3 to the gist. 4 This gentleman, sir, long after you had retired, 5 had identified a bug, and it was a bug that would double 6 up; so, in other words, you would enter, let's say, 7 a £200 British Telecom bill and then the system would 8 think that there were two times £200 British Telecom 9 bills and, similarly, you might put in a £400 deposit, 10 and it would come up as two £400 deposits, and so it 11 would double up deposits and withdrawals and also 12 sometimes liabilities for, let's say, paying a bill. 13 Do you follow? 14 A. Yes. 15 Q. Now, this gentleman whose -- 16 A. Was it a postmaster incidentally? 17 Q. This gentleman was a postmaster, but he was also 18 a computer science graduate, and his family had had 19 generations of postmasters, and he just wanted to help 20 his Mum out because she was not particularly well at the 21 time. So he came in and tried to help her out. 22 He communicated this to both the Post Office 23 helpline and also the Fujitsu helpline, okay; do you 24 follow? 25 A. I do, yes. 76 1 Q. He was told that they were not going to send a memo out 2 to tell people, they were not going to do that, they 3 were just going to let it carry on. 4 That's hardly open and transparent, is it? 5 A. I agree. 6 Q. Now, if you were in charge then, you would not have let 7 that happen, would you, if that had come to your 8 attention? 9 A. Had I known about it individually, yes. 10 Q. Had you known about it -- because now I want to explore, 11 from that problem being notified to both the Pathway or 12 Fujitsu at that time Helpdesk and also the Post Office 13 NBSC Helpdesk, how many layers of management were there 14 before it would have got to you, when you were both, 15 first of all, in your role as roll out manager but then 16 head of BSM? How many parts of the hierarchy would it 17 have to ascend before it got to you? 18 A. Probably three or four, but there was a recognised 19 process for dealing with these. An incident like that 20 should have been referred to Business Service Management 21 to actually do an analysis of that particular problem 22 and to issue a solution. 23 Q. The upshot of that gentleman's evidence was that, to his 24 knowledge, no other subpostmasters were alerted to the 25 existence of this bug? 77 1 A. Well, if he says that, fine. I can't say what happened 2 after I left the business, though. 3 Q. Of course in 2005 you'd been gone for two years, but may 4 I ask you, please, since that time, from information you 5 have read, did you ever become aware of the 6 callendar square bug? 7 A. No. 8 Q. You don't. Well, then I ask you no questions about 9 that. Thank you very, very much, sir, and thank you, 10 sir, for allowing me to ask those questions. 11 SIR WYN WILLIAMS: So is that all the questions for Mr Grey? 12 MS KENNEDY: Yes, Chair. 13 SIR WYN WILLIAMS: Well, thank you very much, Mr Grey, for 14 coming to give oral evidence this morning and answering 15 questions from a number of people. I'm grateful to you. 16 A. Thank you, sir. 17 MS KENNEDY: Chair, that's our only witness for today. So 18 we're back tomorrow at 10 am with Ms Rita Palmer and 19 then Mr Trevor Rollason. 20 SIR WYN WILLIAMS: Yes, Mr Rollason was due to give evidence 21 today, was he not, but there's been some difficulty in 22 arranging that? How confident are we that he can give 23 evidence tomorrow, if you know the answer, Ms Kennedy? 24 Sorry to put you on the spot. 25 MS KENNEDY: Can I put it this way, Chair: reasonably. 78 1 SIR WYN WILLIAMS: Reasonably, all right, and the plan is 2 that we start with Ms Palmer and then, because 3 Mr Rollason is remote, he can carry on after she 4 finishes after a suitable break, yes? 5 MS KENNEDY: Yes, Chair. 6 SIR WYN WILLIAMS: Thank you. All right then. Until 7 tomorrow, goodbye. 8 MS KENNEDY: Thank you. 9 (12.15 pm) 10 (Adjourned until 10.00 am the following day) 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 79 1 I N D E X 2 DONALD SCOTT GREY (sworn) ........................1 3 Questioned by MS KENNEDY .........................1 4 Questioned by MR JACOBS .........................55 5 Questioned by MS PATRICK ........................63 6 Questioned by MR HENRY ..........................68 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 80