1 Wednesday, 1 March 2023 2 (10.00 am) 3 SIR WYN WILLIAMS: Mr Stevens, before you start, 4 I understand the transcriber has Covid but feels well 5 enough to transcribe from home. That's correct, is it? 6 MR STEVENS: I think so, yes. 7 SIR WYN WILLIAMS: So in those circumstances, I think we 8 ought to try to stick fairly rigidly to having a break 9 after about an hour. 10 MR STEVENS: Yes. 11 SIR WYN WILLIAMS: I also understand, just for everyone to 12 know that if we proceed in that way with having more but 13 shorter breaks, it may be that we won't need a long 14 lunch break today and that we'll finish around about 15 1.30. That's not a promise to anyone, but that's 16 apparently how we might proceed. So I'm just letting 17 everyone know. We'll resume. 18 MR STEVENS: Thank you, sir. May I call Ms Allaker. 19 ELIZABETH ANNE ALLAKER (affirmed) 20 Questioned by MR STEVENS 21 MR STEVENS: Thank you, Ms Allaker, as you know my name is 22 Sam Stevens and I ask questions on behalf of the 23 Inquiry. Please can you state your full name. 24 A. Full name is Elizabeth Anne Allaker. 25 Q. Thank you for attending the Inquiry today to give 1 1 evidence and thank you also for providing a written 2 statement to which I would like to turn now. It should 3 be in the bundle of documents in front of you under 4 tab A. For the record, the reference is WITN06200100. 5 Does that statement run to eight pages? 6 A. It does, yes. 7 Q. On page 6, the last paragraph should be paragraph 50 -- 8 A. Yeah. 9 Q. -- and at the bottom should be a signature, is that your 10 signature? 11 A. It is, yes. 12 Q. Are the contents of that statement true to the best of 13 your knowledge and belief? 14 A. They are. 15 Q. That statement now stands as evidence in the Inquiry, 16 I will be asking you some questions on that and other 17 matters as well. 18 A. Okay. 19 Q. Firstly, in terms of background, you held various roles 20 with the Post Office from 1979 to 2001, including as 21 a counter clerk and an auditor? 22 A. Yes. 23 Q. I think you were an auditor in, is it, 1998? 24 A. It was thereabouts, yes, I can't remember the exact date 25 but I think I put what I thought it was in here. 2 1 Q. Were you an auditor prior to the introduction of 2 Horizon? 3 A. Yes. 4 Q. Can you recall at that time where the audit team sat in 5 the Post Office, what department? 6 A. Do you mean whereabouts in the country or in -- 7 Q. No, in the corporate structure. 8 A. I can't, actually, no. 9 Q. In general terms, as an auditor, when would you be asked 10 to investigate a sub post office? 11 A. Well, the audit process was routine anyway, so you try 12 to get round as many offices as you could within 13 whatever the timescales were. On top of that, if they 14 thought there was a risk to funds, if something had 15 flagged up anyway that suggested there might be a risk 16 of funds being lost, then we were asked to attend. 17 Also, for robberies and burglaries, following a robbery 18 and a burglary, there was an audit done of the office to 19 see what any -- 20 MR STEVENS: Sorry, Ms Allaker, can we pause there, there's 21 a problem with the transcript I believe, sir. Sorry. 22 SIR WYN WILLIAMS: A problem in the sense of it not 23 appearing on our screens here or a problem with the 24 transcriber? 25 MR STEVENS: I'm just going to check now sir, I'll just be 3 1 a moment. 2 Thank you. 3 SIR WYN WILLIAMS: It seems to be general consensus it's 4 working now, yes? 5 MR STEVENS: Right. But it's being -- I understand it's 6 being transcribed it's simply not -- 7 MR JACOBS: It's being transcribed because I've got it on 8 own my computer. It's showing on the screens but it's 9 stopped, it's frozen on the Inquiry screens. 10 SIR WYN WILLIAMS: Well, I think I said this on an earlier 11 occasion, if the problem is simply with our screens 12 here, but there is a transcription occurring, I propose 13 to carry on because we can all read the transcription 14 afterwards. 15 MR STEVENS: I'm grateful, sir. 16 I'm told we can refresh the screens in about five 17 minutes, so it should be back on within that period. 18 SIR WYN WILLIAMS: All right, fine. 19 MR STEVENS: Thank you. Ms Allaker, I apologise for that. 20 You were just talking about burglaries, I believe, when 21 I asked you to pause. Can you continue your answer? 22 A. Yes, so there would -- if there was a robbery or 23 a burglary, the audit team were asked to attend to 24 assess what shortfall there was following the robbery or 25 burglary. There would also be audits done if an office 4 1 was transferring from one subpostmaster to another. 2 I think that's probably it. Oh, if the office was being 3 defunded for any reason, perhaps if there'd been -- 4 I don't know what's an example -- a flood or a fire or 5 something like that, then, at that point, often the 6 audit team would be asked to attend then and make sure 7 everything was packed up and checked off before it was 8 defunded, the stock was taken out and cashed. 9 Q. When you said funds at risk earlier, would that include 10 if there was a discrepancy between -- a discrepancy in 11 the account? 12 A. Yes. Yes, that -- if something had flagged up somewhere 13 to suggest that there was a discrepancy, yeah. 14 Q. In practical terms, as a matter of practice, what level 15 of discrepancy would it take to trigger an audit like 16 that? 17 A. Oh, um, I don't know. I don't know whether there would 18 be any particular level. I mean, you'd have -- probably 19 things would have been checked first to make sure there 20 was no transaction corrections or anything due or there 21 hadn't been anything else wrong. It wouldn't always 22 needed to have been a lot, you know, not talking tens of 23 thousands or hundreds of thousands, or anything like 24 that, it could have just been a few hundred or you know, 25 into the thousands. It didn't have to be an awful lot 5 1 of money. It was just the fact that there was 2 a discrepancy there that nobody was getting to the 3 bottom of. 4 Q. Pausing there, I want to pause on this issue of 5 shortfalls. The Post Office contracted with 6 subpostmasters from 1994 on the Standard Subpostmaster 7 Contract. 8 A. Yes. 9 Q. That was modified on occasion. It was -- there were 10 then new terms brought in 2011, the Network 11 Transformation Contract. The questions I'm going to ask 12 now concern the earlier contract, the Standard 13 Subpostmaster Contract. Before I confirm to that, the 14 Inquiry has heard evidence that the Post Office worked 15 on the basis that subpostmasters were required to make 16 good any shortfall that arose in the branch accounts? 17 A. Yes. 18 Q. Would you agree with that? 19 A. Yes. 20 Q. Was that always the case during your time at the Post 21 Office? 22 A. Yes. 23 Q. Where did your basis for that position come from? 24 A. It was always explained that it was because it was 25 a contract for services, then we -- you always referred 6 1 back to the contract and that was quite clearly written 2 in the contract, that any loss, whether it was loss of 3 by the subpostmaster or their assistants, was to be made 4 good by the subpostmaster, if that was the contract that 5 they'd signed. So that was the basis that we work to. 6 Q. If we could bring that contract up, it's POL00000254 and 7 page 33, please. Clause 12 deals with losses and it 8 says that: 9 "The subpostmaster is responsible for all losses 10 caused through his own negligence, carelessness or 11 error, and also for all losses caused by the negligence, 12 carelessness or error of his or her assistants. 13 Deficiencies due to such losses must be made good 14 without delay." 15 Reading that, would you accept that what 16 a subpostmaster is responsible for here is a loss, where 17 it's caused by their own negligence, carelessness or 18 error? 19 A. Yes. 20 Q. That's -- do you accept that's different from 21 a subpostmaster being responsible for any loss howsoever 22 caused? 23 A. I can't think of any other kind of loss that could be 24 caused. 25 Q. Well, if we take in Horizon the example of a discrepancy 7 1 caused by the computer system itself. 2 A. Right, yes. 3 Q. Would you accept that that wouldn't be caused by 4 negligence, carelessness or error of the subpostmaster? 5 A. Yes. 6 Q. So that can be taken down, thank you. The message and 7 the position that Post Office considered subpostmasters 8 would be responsible -- sorry, subpostmasters would be 9 responsible for all losses, you said that came back to 10 the contract, but was there anyone or anyone in 11 management who was reiterating that position, as that 12 was Post Office's position? 13 A. Not necessarily. I mean, because that was the contract. 14 I think probably what I should say here is that, while 15 I worked for the Post Office, whichever role I was 16 doing, that that's the only clause that I remember, and 17 at that point I don't think I or anyone else had any 18 reason to believe that there could be any other way that 19 a loss was caused. So the fact that the Horizon System 20 could cause a loss just wasn't even considered. 21 Q. Moving on, after your counter clerk roles, you took 22 a role in 2001. Could you briefly summarise what that 23 was? 24 A. 2001 ... 25 Q. Sorry, for your reference, it's paragraph 4 of your 8 1 statement. You say -- 2 A. It was in Darlington area office? 3 Q. Yes. 4 A. Yes, that was an administration role, so it was pretty 5 much administrating for -- there was an area manager and 6 I can't remember what all the job titles were at that 7 point but there were a number of people that worked from 8 that office, so it was booking appointments, answering 9 enquiries, that kind of thing. 10 Q. In 2012 you became a contract adviser? 11 A. Yeah. 12 Q. What did that role involve? 13 A. That involved managing contractual enquiries, it could 14 have involved interviewing subpostmasters. 15 Q. What would you have interviewed them about? 16 A. Well, if there'd been a discrepancy at audit for which 17 they'd been precautionarily suspended, I could have 18 interviewed them for that. It could have been in touch 19 with them about sickness, if they needed holiday 20 substitution, that kind of enquiries, that used to come 21 through. 22 Q. So on the interviews, in respect of -- it may be 23 interviews in respect of discrepancies? 24 A. Yeah. 25 Q. You said earlier that you, during this period considered 9 1 that Horizon couldn't cause discrepancies. 2 A. Yeah. 3 Q. Was that a general view held by contract advisers, to 4 the best of your knowledge? 5 A. It would have been, yes, because my assumption, and 6 I presume everybody else's, was that although things 7 didn't always run smoothly in Horizon. There was always 8 some way of recovering or fallbacks to make sure that 9 anything that had gone wrong was put right. So, yes, 10 I would imagine that that would be the case, without 11 speaking for everybody else, but yes. 12 Q. As a contract adviser, were you ever -- did you ever 13 encounter a subpostmaster saying "This discrepancy, 14 I believe it's been caused by the Horizon IT System"? 15 A. No. Not directly, and certainly not during the period 16 that I was a contract adviser. 17 Later, down the line, then, yes, they did start to 18 be people who questioned that, if they did have a loss. 19 Not to me directly but I had heard of that being asked, 20 yes. 21 Q. If, as a contract adviser, you -- someone had said that 22 to you directly, what would your response have been? 23 A. I would have -- I probably would have done my best to 24 try to make them understand that it wasn't possible, 25 that, you know, that whatever had gone wrong we'd 10 1 investigate it and there was no way that it could be the 2 Horizon System because of all the assurances that we 3 got. 4 Q. You say all the assurances you got, can you just expand 5 on that, please? 6 A. Well, we've always been of the impression that anything 7 that did go wrong with Horizon, that somewhere in the 8 background, it was put right. If it had got to the 9 point where a branch had a loss, they would receive 10 a transaction correction for it, or if a branch had 11 a loss that they couldn't explain, there was an option 12 to put it into the suspense account sometimes to see if 13 a transaction correction came back later down the line. 14 But any investigation had never -- or any, you know, 15 looking into losses, had never thrown up anything to do 16 with the Horizon System having caused the loss, so 17 I presume that, you know, we all just trusted what we 18 were told and that a loss couldn't be caused by the 19 system itself. 20 Q. Who gave you those assurances? 21 A. I don't know whether it was just generally everybody 22 said the same thing. I don't know that we necessarily 23 even looked at anybody for assurance. It was just that 24 if that came up ever, that's what we knew: that it must 25 have been mentioned at some point but I cannot honestly 11 1 point to one person and say they did. 2 Q. As a contract adviser, were you involved in intervention 3 visits? 4 A. Going out to a branch myself at that point, no, I don't 5 think I was. I was involved in -- I was involved in 6 intervention visits prior to that, I think. Possibly 7 during my time in the area office. I think I would be 8 asked to help out and go out and visit a branch for -- 9 it could have been a robbery or a burglary. 10 Q. Did you ever go out for an intervention visit because of 11 a subpostmaster was requesting additional training? 12 A. No. No. 13 Q. Did you attend an intervention visit to investigate the 14 cause of a discrepancy? 15 A. Not, I don't think, during my time as a contract 16 adviser. Only during my time at Audit -- in the audit 17 team, I think. 18 Q. So 1998, pre-Horizon? 19 A. Yeah, yeah. 20 Q. I want to move on in the chronology to October 2013. 21 Please could we bring up POL00043370. This is 22 an attendance note for a meeting on 9 October 2013, it's 23 on Bond Dickinson headed paper. Are you aware of Bond 24 Dickinson's role in relation to the Post Office? 25 A. Yes. 12 1 Q. And that is? 2 A. Bond Dickinson were legal representation for the Post 3 Office. 4 Q. We see in the attendance list there are "Legal", Rodric 5 Williams, head of Post Office legal, was he, at that 6 point? 7 A. Mm-hm. 8 Q. Martin Smith of Cartwright King. Do you recall his 9 role? 10 A. I don't recall his role, no. 11 Q. We see at "Network", you're in attendance -- 12 A. Yeah. 13 Q. -- and Gayle Peacock as well -- 14 A. Yeah. 15 Q. -- Nick Beal. For the NBSC, it says that you're there 16 on behalf of Kendra Dickinson? 17 A. Yeah. 18 Q. At this stage in 2013, were you involved with the NBSC? 19 A. Yes, I used to work quite closely with the NBSC, to 20 try -- well, try and make improvements to the way the 21 structure was and to make improvements to -- I can't 22 remember at that point whether the Branch Support Team 23 was still there, but I sort of linked between the two of 24 the teams, the Branch Support Team if they were still 25 there then, they were still part of the Network teams. 13 1 Q. We'll come on to that in a moment but, in broad terms, 2 yes involved -- 3 A. Yes. 4 Q. -- but as a sort of oversight of what could be improved, 5 rather than taking calls yourself? 6 A. Yes. 7 Q. If we could just go down on this attendance note to see, 8 it refers to a number of issues in branches, which we 9 don't need to go into detail, but my question is: what 10 was the purpose of this meeting? 11 A. I think would this be one of the meetings that were 12 held -- I don't know whether it was monthly -- to try to 13 just make sure that anything that was coming in on -- 14 that was referenced to the Horizon System or any losses, 15 or anything like that, that they'd had -- they didn't 16 overlap with anything that was going on with the 17 Inquiry? Had the Inquiry started by this point? 18 Q. Not at this stage. There was a Second Sight, this was 19 around the time when Second Sight was -- 20 A. So it would be to make sure -- that's probably what I'm 21 thinking of, then -- that we didn't overlap with any of 22 the cases that were going on in Second Sight and that 23 also were starting to take any learnings from cases that 24 came up to make sure that, if there was things falling 25 through the net anyway, that we were more likely to pick 14 1 them up. Whether it was to do with the Horizon or 2 looking at this, some of it was more general things 3 anyway. 4 Q. So these were operational issues, discrepancies and the 5 like -- 6 A. Yeah. 7 Q. -- which were being discussed in a context with legal 8 representatives at the Post Office -- 9 A. Yes. 10 Q. Do you recall what the -- what sort of issues the legal 11 team were interested in? 12 A. Um, not in detail, no. I mean, if I hadn't had the 13 documents I would probably have struggled to remember 14 most of the things that were discussed but, looking at 15 some of this, then there was certainly things that, you 16 know, people were starting to say had linked to Horizon 17 then. But, no, not specifics of anything, no. 18 Q. Slightly different question. Do you recall if the legal 19 team gave any advice on operational issues, such as what 20 to do with the loss? 21 A. Not that I remember. I think their advice was more 22 legally based. But that's just memory. I'm picking up 23 there. 24 Q. If we can go to a different document, please it's 25 POL00002276. At the top it says, "Horizon Service 15 1 Improvements Workshop" and it's 5 September 2013, so 2 a month before but around the same time as the legal 3 meeting we just saw. Do you recall the purpose of this 4 meeting? 5 A. Yeah, vaguely. I think this meeting was set up because, 6 by this point, we were starting to get input from -- 7 well, the NFSP had mentioned improvements for a number 8 of years and I can't remember whether we also had the 9 branch user forum set up then, which was a little, small 10 group of subpostmasters who used to attend a meeting 11 quarterly. We'd set that little group up to try to get 12 more input from subpostmasters. They used to go and 13 talk to their own representatives. 14 So I think the NFSP, the branch user forum and 15 possibly other sources were all saying that there was 16 improvements that they would like to see, and this 17 workshop was to try to kick off some of that with 18 Fujitsu. It was at Bracknell, wasn't it? Yeah. So it 19 was to try to get them to understand, from the 20 subpostmaster's point of view, what improvements they 21 wanted going forward. 22 Q. We see there in the attendee list NFSP, Jim Nott, 23 postmaster. 24 A. Yeah. 25 Q. Do you recall how that postmaster was selected? 16 1 A. No, if my memory is correct, there was more than him 2 actually due to attend but, for whatever reason on the 3 day, Jim was the only one that did attend. I don't know 4 whether there'd been another meeting come up or what had 5 happened, but I'm pretty sure there were other people 6 that were asked on behalf of the NFSP and Jim was the 7 only one that could make it. 8 Q. You've mentioned about the NFSP and there being calls 9 for improvements for a while. Can you recall if there 10 was an immediate trigger which caused this meeting to be 11 arranged? 12 A. Not to my knowledge. Not an immediate trigger. 13 Q. Please can we turn to page 4 and section 1.5. This 14 talks about "Rem Out for End of Day Cheque Processing". 15 Can you just explain very simply what that is? 16 A. Yeah, at the end of the day, you used to have to rem 17 your cheques out and a lot of that depended on when 18 the -- when your collection was from Royal Mail because 19 they used to have been to be dispatched manually, so you 20 used to have to cut them off and rem them out then, and 21 then I don't know whether on a balancing day, or -- was 22 it every day or just on a balancing day? I'm testing my 23 own memory now -- they used to have to be remmed out 24 again or something had to be done, definitely, at 25 balancing. 17 1 I think the reason that that one was on the list, 2 for looking at improvements, was because it was a bit of 3 a clunky process, so there seemed to be a number of 4 steps that you could go through and it wasn't always 5 intuitive, particularly, I suppose, if you were a new 6 subpostmaster. So I think it was there to look at 7 seeing if it could be done any slicker through the 8 system. 9 Q. If we just turn the page, if we can, to the top of the 10 next page, please. It says: 11 "This is a lengthy process, and unnecessarily runs 12 the report twice. It also increases the potential for 13 the clerk to enter an amount which does not match the 14 report total amount." 15 So is what this is saying is that the process 16 increased the risk of discrepancy caused by user error? 17 A. Yes, it could. Because anywhere that you could just put 18 a number in yourself, there's always the chance that 19 you're going to hit a wrong key or, you know, something 20 else could go wrong. 21 Q. If we go down slightly, we see there are some suggested 22 improvements. Do you recall if those were brought in? 23 A. I can't, actually, no. I know that we did some more 24 work on that, on the cheque rem out process, but I can't 25 remember honestly whether improvements did actually come 18 1 in or not. 2 Q. So things like this, where improvements to make the 3 system easier to use and potentially reduce error, were 4 those findings of where there may be increased risk of 5 user error, were they communicated to anyone in the 6 audit team or the prosecutorial team? 7 A. Not communicated to, but I would say that the people in 8 the audit team all knew of the processes where -- that 9 were a bit clunky, really, that, you know, where it was 10 likely that an error could be, so let's look there 11 first, to make sure that there's not anything wrong. So 12 the cheque rem out system would be one of the ones they 13 would look at. They would always look at things like 14 that to make sure that cheques had been remmed out, that 15 they'd been remmed out correctly, et cetera, et cetera. 16 Q. So, in effect, is your evidence that where there were 17 let's call it design issues, which increased the risk of 18 a user error, the audit team would be well aware of 19 that? 20 A. I would say so, yes. 21 Q. If we turn to page 6, please, and paragraph 2.4. This 22 relates to "Transaction Correction Print Out", and it 23 says: 24 "The postmaster needs to be able to see which 25 Transaction Corrections have been processed and which 19 1 are outstanding." 2 If we can turn the page, the suggested improvement 3 in this case is that: 4 "This report is already available, and so this 5 improvement is considered to already be present." 6 It goes on to discuss revisiting communications on 7 this. 8 At this stage, were you aware of any subpostmasters 9 who were calling for more access to, say, audit data or 10 transaction data, used by the Horizon IT System? 11 A. To answer that question I'd probably have to say that, 12 yes, there was always a desire that I'd found from the 13 subpostmasters that I spoke to, that they had improved 14 ways of looking at the system themselves. So whether it 15 was to do with transaction corrections. And I don't 16 know -- when it says "is considered to be already 17 present", I'm not disputing that. 18 That opportunity must have -- may have been there, 19 but then, clearly, in this case, what we needed to do 20 was recommunicate that here's a report that you can get. 21 A lot of subpostmasters would want as much information 22 as possible, so would have been asking for -- you know, 23 would be asking if they could get a report on X, Y and 24 Z. So, yes. 25 Q. Do you know if that was ever a point of discussion with 20 1 Fujitsu as to whether that would be a possibility of 2 allowing postmasters access to such data? 3 A. It was, because I think I have been there when those 4 conversations were had. As a result of this, and then 5 also doing some work on what we ended up calling HORice, 6 which was a tool to investigate certain transactions and 7 reports and things, ultimately, the desire for HORice 8 would have been for subpostmasters to have access to 9 that type of reporting and, I think, at the time, not 10 long before I left, these things were being discussed 11 more often because we were hoping for new technology to 12 be coming in or new systems to be coming in, so that we 13 could get subpostmasters access to more information and 14 it would be more -- more of a two-way thing. 15 Ultimately, what we wanted was for subpostmasters to 16 be able to communicate with us online and I got the 17 impression that that's what subpostmasters wanted to do 18 as well, and once we'd got to that sort of state, we 19 were hoping that we'd be able to share some of the 20 things that we were starting to build ourselves. 21 Q. I was going to come to HORice later but it makes sense, 22 since you've mentioned it now, to go there. HORice is 23 H-O-R-I-C-E, and was that an acronym for something? 24 A. It was but I can't remember what it was, if that's the 25 next question. 21 1 Q. In paragraph 5 of your statement, you say that you 2 worked on building an enquiry system known as HORice 3 which was to build new reports to try to improve the way 4 information could be obtained from the system to handle 5 enquiries. Presumably the system there is Horizon? 6 A. Yes. 7 Q. Do you recall when HORice was introduced? 8 A. No. I can't. I can't put a date on it. 9 Q. In broad terms, would it have been earlier or later 10 than, say, 2013? 11 A. Later, I think. 12 Q. What information was available or stored in HORice? 13 A. It was all transactional data and report data but it 14 was -- what we were trying to do was get reports for 15 things that we hadn't already had, and I can't 16 remember -- I can't even tell you what an example would 17 be of one. Just so that if there was a discrepancy or 18 you needed to look for something or you needed to find 19 something more quickly, then you could get a report from 20 this new HORice system that we'd got. 21 Q. So would that include the transaction logs for 22 a particular branch? 23 A. Well, you could get transaction logs anyway, so 24 subpostmasters did have access to printing off 25 transaction logs, if I remember correctly. But only for 22 1 a certain length of time, and I think that's one of the 2 things that we were wanting to change. I don't know 3 that was directly within HORice. But it was, certainly 4 HORice was asking for stuff to be available for a longer 5 period of time, so that you did have something that you 6 could go back and refer to. 7 Q. What length of time are we talking here? 8 A. I think HORice was only -- the transaction logs were 9 only available in branch, I'm going to say, for a month. 10 Whether that's right or not I don't know. If that's the 11 case, I think we were asking for six months, and 12 possibly even longer than that. Having said that, 13 I think there was -- there was going to be a limit to 14 what we could get because of the volume of transactions 15 that went through the system. I don't know that 16 whatever clouds these things all go to were going to be 17 big enough to hold everything for that length of time. 18 Q. We spoke about transaction logs. Would HORice store 19 things beyond that? So would it include actually just 20 the data in a branch that Horizon used to generate 21 branch accounts? 22 A. I don't know. I think what I would say here is that 23 that information was there somewhere, the information 24 that we were asking for in Post Office. So whether it 25 was for the Finance Service Centre, whether it was 23 1 something that was going to help subpostmasters 2 themselves, whether it was the security team or whoever 3 that was suggesting the types of reports that we were 4 asking to be implemented in HORice, that information was 5 clearly there, otherwise Fujitsu would have said, "We 6 can't do that because we haven't got that type of 7 information stored". 8 So we were asking for stuff that was there, just 9 either in a better format for a longer period of time or 10 in a different way to allow us to look at our own 11 system. 12 Q. For easier access? 13 A. Yes. 14 Q. Who was given permission to access HORice? 15 A. There were only -- I think at the time that I left, 16 there were only about 18 licences, if it was that. 17 There was a very small number of licences because 18 I think it was still being trialled. 19 Q. What was the reason for not giving access for 20 subpostmasters to the data relevant to their own branch 21 through HORice? 22 A. I don't know. I know that we only had a very small 23 number of licences at that time. Ultimately, 24 discussions were ongoing with Fujitsu to either extend 25 the number of licences or to progress the trial further, 24 1 but then it was going to be -- yeah, I think it was cost 2 after that so it would be, you know, we'll have to start 3 talking about money for additional licences and how many 4 do you need, and ... 5 Q. Moving on from HORice, we'll go to the Branch Support 6 Programme which I believe you were involved with. 7 A. Yes. 8 Q. What was your role in that? 9 A. I'd probably have been doing a number of jobs within the 10 Branch Support Programme. I did use to facilitate the 11 Branch User Forum. Um, I can't remember any specifics. 12 I did an awful lot of stuff -- it was a lot about trying 13 to work with the communication team, work with different 14 parts of the business to try to get, you know, 15 improvements to what we were doing and how we were 16 communicating, so that it was easier for subpostmasters. 17 Just working throughout the business. 18 Q. Let's take it in stages. Do you remember when this 19 programme started? 20 A. I can't remember exactly the date that it started, and 21 because the programmes tended to change names, we did 22 like to have a change of name every now and then and 23 I can't remember which programme ran into which one now, 24 so sorry. 25 Q. If I suggested around 2013 or '14, would that ring true? 25 1 A. I wouldn't be able to argue one way or another. 2 Q. You refer to the Branch User Forum, I understand that is 3 where subpostmasters were invited to provide feedback on 4 the Horizon System and Post Office processes generally. 5 A. Yeah. 6 Q. How many subpostmasters were involved? 7 A. In the Branch User Forum? 8 Q. Yes. 9 A. About six subpostmasters, I think. 10 Q. How were they selected? 11 A. Um, I think there was -- I think it was through the 12 branch focus, the communications team. There was 13 an article went out in that inviting people to apply and 14 then, from the applications, somebody, I don't know who 15 or how, selected the people that would first use -- you 16 first come in on the Branch User Forum but I think it 17 was an annual changeover, so the plan was that it was 18 going to be changed annually and it was people came out 19 and went in. 20 So you weren't there indefinitely. 21 Q. Please can we turn to POL00039215. So this is a Branch 22 Support Programme PowerPoint presentation in May 2014. 23 Are you aware of a mediation scheme for subpostmasters 24 who were alleged to have shortfalls caused by like 25 Horizon? 26 1 A. I'm aware of it, yes. 2 Q. Were you involved in it? 3 A. No. 4 Q. Was there any link between the Branch Support Programme 5 and either Second Sight or that Mediation Scheme? 6 A. The link would be -- well, people? I don't know. 7 I don't know whether there was any direct link between 8 the people that worked in the Branch Support Programme 9 and the Mediation Scheme. There would -- I knew, 10 certainly, the people that worked in the Mediation 11 Scheme. Whether or not they were all part of the Branch 12 Support Programme at the same time or we were all under 13 this same umbrella, I wouldn't be able to say from 14 memory. 15 Q. Do you know what triggered the Branch Support Programme 16 to be implemented? 17 A. I think it was probably the ongoing need to have some 18 sort of, I would say, a culture change within Post 19 Office. I think it was more or less along the lines 20 that we weren't engaging with people as well as we 21 could. It didn't feel like, at the time, that 22 everybody's voice could be heard and the Branch Support 23 Programme was probably grown out of that. 24 Q. If we turn to page 3, please -- sorry, page 5. No, it 25 was in between. Page 4, sorry. 27 1 This refers to -- it says one of the issues of the 2 report, which is referring to the interim report of 3 Second Sight -- it says the following: 4 "Lack of timely, accurate and complete information 5 provided to subpostmasters to support them in resolving 6 issues. 7 "Lack of centralised data or files specific to each 8 branch which hinders a quality investigation from taking 9 place." 10 At the bottom we see: 11 "The investigation undertaken by the Programme 12 highlighted/confirmed the following issues: 13 "Inconsistent record keeping by internal teams or 14 contact made with branches 15 "Inconsistent quality of information retained by 16 teams 17 "Lack of consistent processes or workflows between 18 teams within a process 19 "Lack of timescales to resolve branch issue, coupled 20 with lack of monitoring of issues 21 "Inconsistent sense of 'ownership' of different 22 issues." 23 From this, is it fair to say that the Branch Support 24 Programme wasn't engaging with subpostmasters on alleged 25 bugs, errors and defects in the Horizon IT System? 28 1 A. I think I would say that it's probably fair to say that 2 no, we weren't, because bugs, errors and defects were 3 more IT issues. If we'd needed to do anything about 4 that, and I'm not saying that we didn't because, you 5 know, certainly things did occasionally crop up that 6 were described to me as bugs, errors and defects, that 7 would have been more in Fujitsu's domain. 8 Q. So outside of your responsibility? 9 A. Yes, in that it's not something we would have been able 10 to fix but I suppose, as part of working on HORice and 11 working on the Branch Support Programme, I think it's 12 probably fair to say that, looking to the future, what 13 we would want is a system, bug, error and defect free, 14 of course, but that's probably not possible in IT world. 15 So while it wasn't there on that list, if you like, it 16 would be something in the back of our minds. 17 Q. But I suppose more in terms of the Branch User Forum, 18 which this was involved with, the subpostmasters there, 19 there was no discussion with subpostmasters of branch -- 20 sorry, bugs, errors and defects in the context of the 21 Branch User Forum? 22 A. Not that I recall directly, no. 23 Q. Were you involved in any steps to be taken to address 24 the issues that you identify in this slide? 25 A. Well, in that, yes, there were number of things that we 29 1 tried to do within the Branch Support Programme, through 2 either NBSC and Branch Support Team, if they were still 3 around at the time, that would help engage more with 4 subpostmasters. So we did things like we could get 5 reports from NBSC on the number of people that called in 6 to NBSC, what the issues were they called in on. So 7 like which branches called in most often. Which 8 branches didn't call in at all. 9 And during the time that the Branch Support 10 Programme ran, and afterwards, we used to make calls to 11 branches from those lists to make sure that, you know, 12 was there anything that we could do to help. So if it 13 was somebody that was ringing in a lot of the time, it 14 was to try to make sure that, if they were new, new 15 subpostmasters, was there any additional help they 16 needed? Was there any more support that we could get 17 them, whether that be through a bit more regular contact 18 from an NBSC adviser or, you know, ultimately we could 19 put a request through perhaps to get a bit more 20 training. 21 I think we had calls to branches that had never rung 22 in to us at all. So that -- because clearly, you know, 23 they were still a valuable part of the Post Office, as 24 far as we were concerned but for years they hadn't been 25 engaged with, if you like. So they were rung. 30 1 Q. Shall we look at the NBSC now on that point. If we can 2 turn to POL00090223, which is an email that you sent to 3 Angela van den Bogerd on 6 May 2015. You say you attach 4 a one-pager, it's actually a two-sided one-pager, on the 5 NBSC employee comments, which we will come to in 6 a moment, it's feedback. Why were you providing 7 feedback to Angela van den Bogerd at this stage? 8 A. I don't know. I think it was this one, all I'd done was 9 pull the information together from my contact with NBSC, 10 who I think that was the -- that was where the 11 McKinsey's feedback had been involved or was referring 12 to. Because I didn't ever see the McKinsey's report 13 myself, I'd just heard about it. So I'm guessing, from 14 this, that that all I'd done was pull something together 15 and give it to Angela as a two-pager on something that 16 she'd asked for. 17 Q. Do you recall why she asked for it? 18 A. I can't, no. 19 Q. Can we go to the next page, please. We have some 20 comments here and the first one -- it says "81 comments 21 in total broken down as follows": 22 "Communication -- 14 comments. Main theme relates 23 to timely and better communications and also knowledge 24 of what to do when products are launched or when things 25 change or go wrong. This theme was raised with Branch 31 1 Support Programme and is a theme raised by BUF too." 2 "BUF" being? 3 A. Branch User Forum, yes. 4 Q. So is it fair to say that the feedback you've pulled 5 together here was criticising the level of information 6 and communication to the NBSC relating to both changes 7 to Horizon and problems with Horizon? 8 A. Not necessarily with Horizon, there, no. In fact, 9 I would say probably not with Horizon. It was to do 10 with communications that went out to branches, in the 11 Branch Focus, I think it was called Branch Focus, 12 communication that went out weekly. 13 NBSC should always have seen -- well, I'm saying 14 "always", there may be things that they didn't need to 15 see but they should have always had the opportunity to 16 see and comment on the communications that went out to 17 branch before it went out, purely and simply because 18 they were the ones that were going to get the enquiries 19 if the communication wasn't clear. So they could then, 20 you know, act as the go-between between the 21 Communications Team and subpostmasters, to some extent. 22 And I think what, from memory, what that would be, 23 would be the advisers in NBSC would be saying, "We're 24 either not getting them or we're not getting them quick 25 enough to do something about it" or, you know, maybe 32 1 "We've fed back on this but nobody has picked anything 2 up or not replied to say why they haven't done anything 3 with our feedback". 4 So I think that would be more to do with products 5 and transactions than anything to do with Horizon 6 itself, with the system. 7 Q. And the final sentence says, "AHT"; do you remember what 8 that stands for? 9 A. Average handling time. 10 Q. So is that the time in which it takes for a member of 11 the team to resolve a call? 12 A. Yes. 13 Q. So: 14 "AHT was also raised as an issue by advisers in that 15 they feel they are pressurised to achieve AHT above 16 quality of response to branch." 17 Do you recall that being a concern at the NBSC? 18 A. I recall it being mentioned but I don't know that that's 19 a fair comment because I don't know the context that it 20 was given in. 21 Q. Do you know what the average handle time aim was? 22 A. No. I'm saying no, I will have heard it in the past, 23 but I can't remember what it was, and I would imagine 24 that over years, it probably changed anyway, you know, 25 as average handling time it would be if things were 33 1 improved in NBSC, that if things were quicker for the 2 advisers to get to, then I would imagine that over the 3 years that average handling time would have changed. 4 Q. So in your position, we see that the BUF and the Branch 5 Support Programme looked at the NBSC. Did you have any 6 concerns during that period as to the quality of the 7 advice that the NBSC was able to give to subpostmasters? 8 A. No. 9 Q. Why not? 10 A. Because the advice that the NBSC gave to subpostmasters 11 was always given to them so they had a massive Knowledge 12 Base that they could go to, to look at. If -- the only 13 thing I would say would have been of concern would have 14 been if there were more than one way that they could get 15 to the answer, for something. So say somebody rang up 16 about Lottery for the sake of picking -- and the adviser 17 hadn't understood exactly what the Lottery question was 18 and had gone into the wrong bit of the Knowledge Base, 19 then that would have been the only thing that would have 20 been a concern. Not the actual -- it would be that 21 they'd given the wrong bit of advice for the wrong 22 transaction -- for the right transaction, rather than 23 they had any concern about the advice they were given. 24 What was on the Knowledge Base was right, providing 25 that the advisers went through it to the right bit. 34 1 Q. Turning to a different topic now, at page 4 of your 2 statement onwards you referring to the Horizon weekly 3 call. Do you remember when this was set up? 4 A. No. 5 Q. Do you know why it was set up? 6 A. Yes, again, I think that was the one that was set up so 7 that we weren't duplicating anything that was going on 8 with the Second Sight branch of -- 9 Q. What do you mean "duplicating"? 10 A. Well, if the branch was in Second Sight or later on, 11 whatever, it went into mediation -- I can't remember 12 exactly what happened when -- it was to make sure that 13 we weren't then trying to do something with that branch 14 that was already going on somewhere else, or if there 15 was an ongoing Inquiry, say within the security team or 16 within the Finance Service Centre, that, you know, they 17 were already aware of, that we weren't then duplicating 18 something that somebody else was already looking into. 19 Q. Who attended those calls? 20 A. Horizon weekly call, it would be representatives from 21 Legal, Network, or whatever we were called then, Finance 22 Service Centre, Fujitsu, perhaps Fujitsu, ATOS, by that 23 point as well, and Security, have I mentioned them? 24 Q. Yes. 25 A. I can't remember off the top of my head whether there 35 1 would be anybody else but it was representatives from 2 different parts of Post Office, Fujitsu or ATOS and 3 Legal. 4 Q. Would this call lead to -- or lead to action points to 5 be implemented in respect of how subpostmasters, queries 6 or discrepancies needed to be answered? 7 A. It could, I suppose, if something had cropped up that, 8 you know, say if it had cropped up and it was an action 9 point for me or whoever and somebody else could then 10 answer the question where I couldn't, then, yes, it 11 would -- you know, it would be then used to go back and 12 answer that subpostmaster. 13 MR STEVENS: Sir, that's probably a good time to take 14 a break. 15 SIR WYN WILLIAMS: Certainly. 11.10. Thank you. 16 (10.59 am) 17 (A short break) 18 (11.10 am) 19 MR STEVENS: Thank you, sir. Please could I bring up 20 POL00002396 and go to page 2. We have an email from 21 Andrew Morley to -- well, it's to the Branch Support 22 Team but we see you pick up the email above, 23 11 September 2014. 24 It refers to receiving a call from someone at the 25 branch, and it says: 36 1 "He has seen the BBC report concerning the system 2 issues and is claiming that his system is corrupt. He 3 wants all the money pack from previous discrepancies 4 which he has put in so he could balance. He has been to 5 Horizon/ATOS who have checked everything and can find no 6 system issues but he is adamant it's a system issue." 7 Above you say: 8 "This will be picked up by the Contract Adviser not 9 by an intervention visit." 10 Stopping there, can I just ask why that was 11 a contract adviser issue rather than an intervention at 12 this point? 13 A. I'm guessing that once we'd looked at the branch file on 14 the electronic filing cabinet, that it was something 15 that the contract adviser was already in discussion with 16 this particular subpostmaster about. So again, to avoid 17 duplicating work or avoid NBSC picking up something they 18 didn't need to, it would be -- this was correct for it 19 to go to the contract adviser, the most recent request. 20 Q. Do you recall seeing the BBC report that's referred to 21 here? 22 A. I didn't watch it, no. I remember that it was on but 23 I don't think I actually watched it. 24 Q. Do you recall any discussion in the Post Office at that 25 point on what that BBC report contained? 37 1 A. Um, well, yes. It wouldn't be fair to say that I didn't 2 hear anything, but, yes, people were -- there was a sort 3 of general what's going on here, you know. Where's this 4 coming from. Could any of this be right? But I think 5 we were all still really assured that there was no issue 6 that we need to be worried about. 7 Q. Could we turn to WITN06380101, the email at the bottom, 8 please. It says from Communications Team to 9 Communications Team, and it references "Media coverage 10 on Post Office IT system" on the same day as the 11 previous email we went to: 12 "You may be aware of some media coverage about the 13 Post Office's Horizon System, relating to the contents 14 of some confidential documents, and this may prompt 15 questions from postmasters you speak to. 16 "We are challenging the reporting of this matter as 17 it implies we acknowledge there are systemic faults with 18 Horizon. This absolutely not the case. 19 "Although we will not comment on the contents of any 20 confidential documents, after two years of investigation 21 it remains the case that there is absolutely no evidence 22 of any systemic issues with the computer system which is 23 used by over 78,000 people across our 11,500 branches 24 and which successfully processes over 6 million 25 transactions every day." 38 1 Do you recall receiving a communication like this? 2 A. Yes. 3 Q. Was this consistent with the type of messaging or 4 assurances you said you were receiving? 5 A. Yes. 6 Q. I think your evidence already is you were assured by 7 these sorts of communications? 8 A. I had absolutely no reason to doubt that, you know, we 9 were doing all the necessary due diligence ourselves and 10 that what we were being told was the case. 11 Q. Do you think that was the same for your colleagues -- 12 A. Yeah. 13 Q. -- that they were similarly assured by that? 14 A. Yes. 15 Q. If you hadn't received these assurances, do you think 16 that would have changed the way you approached 17 subpostmasters, such as the one we went to before, who 18 were saying, "I've got a problem, I think it's a system 19 issue, look at this BBC report"? 20 A. Um, I think I would have probably thought a little bit 21 more about it but I still think that, personally, I was 22 quite assured anyway, without being given the 23 reassurance from the Post Office, if you like, because 24 it was a general message that went out. I was quite 25 trustful of the Horizon System anyway, so I don't know, 39 1 yes, I would never have doubted that anyone had concerns 2 and I would have done everything I could to alleviate 3 them, but I certainly wouldn't have been saying "Yes, 4 I think there's something in what you're saying here", 5 because I had no evidence to suggest that there was any. 6 Q. If we go to a different document, please. It's 7 FUJ00120885. Can we turn to page 3 of that document, 8 please. Thank you. The email at the bottom is from Ian 9 Humphries. Do you recall who he was? 10 A. Yes. 11 Q. Who was he? 12 A. He used to work in Service Management, in Post Office 13 Limited, and I think he went across to ATOS. 14 Q. He refers to: 15 "The Meanwood branch has reported an issue with 16 a Health Lottery transaction that is now preventing the 17 terminal from connecting. 18 "Fujitsu is requesting for an authorisation for them 19 to remove the Health Lottery [transaction, and then the 20 number] which is preventing successful recovery on 21 counter node 04." 22 At this point, what's your understanding of the 23 problem facing this branch? 24 A. At this point, if I'd just been reading this, I'd have 25 been wondering exactly what they were talking about. 40 1 For me, there's not enough detail there to tell us 2 exactly what's gone wrong. It might be quite clear to 3 the person looking at it from the other end, I don't 4 know but I don't really -- I didn't really understand, 5 then, what the implications of this was, so I didn't 6 know whether it was having any effect on the branch 7 account, I think, initially. 8 I wouldn't have known whether or not the 9 subpostmaster knew anything about it, unless it was one 10 of the ones that had been raised to me by the Branch 11 Support Team, in that they'd got a request through, as 12 well. 13 Q. We see just towards the bottom it says: 14 "Authorisation is required urgently to enable the 15 postmaster to get the node back online." 16 So, in effect, is the Branch Support Team being 17 asked to authorise a deletion of a transaction from the 18 branch accounts? 19 A. They'd been asked to go to an area manager, who I don't 20 know what they would mean by an "area manager" at that 21 point, but they'd clearly been asked to -- or somebody 22 has been asked to get something authorised to get 23 this -- to get the node back online. That's the, 24 I presume, the counter terminal. So I'm guessing that 25 this would mean that the terminal, that counter 41 1 position, they wouldn't be able to use, because of 2 whatever the problem was. 3 Q. If we look at your response at page 2, please. It's at 4 the bottom. You ask for someone to provide you: 5 "... with the process that was followed for this 6 type of enquiry prior to Service Integration ..." 7 A. Right. 8 Q. What was "service integration" here? 9 A. This must have been when Service Management transferred 10 over their work to ATOS. So, for example, Ian and 11 Sharon, there's another name I remember, Rebecca Barker. 12 They all worked in Service Management but I think they 13 all went across to ATOS, when service integration came 14 in. 15 Q. So those people had dealt with the authorisation before 16 that -- they were then TUPE transferred out and is your 17 query now who deals with the authorisation? 18 A. Yes, but whether or not they'd actually dealt with 19 authorisation before they TUPE'd across, I don't know. 20 I was just hopping that they would have a process 21 somewhere that would tell me where that sat, because if 22 I'm right I don't believe that NBSC or Branch Support 23 Team or anybody had a process for sorting out how we 24 will get this back online. 25 Q. If we go to the next page, please, just to finish off. 42 1 So you say: 2 "... and who the escalation point(s) were? This 3 type of request has not formerly been managed by the 4 Branch Support Team and if it needs to be embedded into 5 a ..." 6 Is that "business as usual"? 7 A. Business as usual, yes. 8 Q. "... environment I would prefer to understand the 9 background to the process, where it should sit (based on 10 earlier cases) so that enquiries are dealt with 11 consistently and are fully documented for audit 12 purposes. 13 "Please provide me with some understanding of how 14 often this happens, root causes, potential solutions, 15 impact to branch/customer and whether there's any 16 financial implication." 17 Are you here asking about the process generally for 18 whenever Fujitsu sought to make amendments to branch 19 accounts? 20 A. Yes. In -- well, I presume that this was -- that this 21 issue itself, in this case, hadn't just come out of the 22 blue, that it wasn't the first time that it had ever 23 happened. And, even if it was the first time it had 24 ever happened, then surely somebody somewhere would have 25 been able to give me some background and say, "Well, you 43 1 know, we can't give you any background on it other than 2 this specific case". They would have been able to, 3 I presume, give me some sort of root cause, in their 4 words I've got used to using, and somebody somewhere 5 would have been able to give us an idea of whether or 6 not there was any impact to the branch as a customer. 7 Because it could be that -- if it was a bill -- did they 8 say Health Lottery? 9 Q. Health Lottery, yes. 10 A. In that case, if they'd got that Health Lottery ticket, 11 or whatever it was, was it a prize from the Health 12 Lottery? I don't know. So were they still out of 13 pocket or was the branch being affected, other than not 14 being able to use that counter terminal, really. 15 Q. Can we go to page 1, please, of this document. 16 SIR WYN WILLIAMS: Just I think there's probably a break in 17 the transcription service. 18 MR STEVENS: Sorry, sir. 19 SIR WYN WILLIAMS: As I say, provided the transcriber is 20 transcribing, I think in the room we'll just have to put 21 up with it. 22 MR STEVENS: Yes, I am told it's fine. 23 SIR WYN WILLIAMS: Yes. 24 MR STEVENS: Thank you. 25 Here's an email you sent to Ian Humphries, the 44 1 second paragraph. You say: 2 "I'm therefore happy to authorise this session to be 3 deleted so that the kit at the branch can return to BAU 4 state." 5 Earlier when you saw the information you had, the 6 transaction detail and what was being required, it's 7 fair to say that, in terms of the technical aspects of 8 it, you didn't have a good grasp of that; is that fair? 9 A. Yes. 10 Q. Did you seek any IT input into whether that was 11 an appropriate decision -- appropriate action to take? 12 A. The IT input then would have come from ATOS. So from 13 Ian or whoever was working on that side of it now in 14 ATOS. That's where it would have come from and it would 15 have been up to them to go to Fujitsu to get anything 16 more that was needed. We didn't have, by that point, 17 for day-to-day enquiries, we didn't have a direct route 18 into Fujitsu, so it was all done through ATOS. 19 Q. Were you responsible for authorising these types of 20 transactions in the future? 21 A. No, I think at that point, once we'd established that 22 there was no impact to the branch financially or to the 23 customer, that the customer was okay with everything, 24 because there was no clear process and nobody was coming 25 up with one, I think what we did was say, "Right, we'll 45 1 authorise it". 2 Because it was important for the branch to get that 3 counter position back up and running, (1) so that they 4 had somewhere to serve customers from, if it was -- 5 heavens forbid, it wasn't just a one-position branch, 6 I don't think. But if it was a two-position branch and 7 they had busy periods, they would clearly need to have 8 that second position up and running. So if that wasn't 9 up and running correctly, it needed to be, plus they 10 would have to reach a point where they would need to 11 roll that position over properly, I think. 12 So they would need to be back online to do that, so 13 that information didn't get lost or fall into the wrong 14 trading period or something like that, whatever could go 15 wrong. So I think what we've done is say, "Right, we'll 16 do this so we can follow the whole thing through and 17 then try and get a BAU process for this, so that we know 18 in future where it needs to go to get authorised". 19 Q. Right. That BAU process didn't result in you being the 20 authoriser? 21 A. No. 22 Q. So is your evidence then that until the ATOS TUPE 23 transfer, there was some sort of process in place for 24 authorising these types of remote access requests. 25 There was then a period of time when there was no BAU 46 1 process but, after this, something, some procedure was 2 put into place but you weren't involved with it? 3 A. Yes, that's assuming that there had been cases of this 4 beforehand and I still don't know that I ever got to the 5 bottom of how many of these there was. 6 Q. Right. Please can we bring up FUJ00085864, page 7 of 7 that document, please. This is an email from Katie 8 Austin to Kendra Dickinson and Ibrahim Kizildag, and 9 this refers to what's now known as the Dalmellington bug 10 or the outreach bug. Is this a fair summary that 11 an outreach service was where there was a core Post 12 Office branch, known as a core branch and there may be 13 a separate sight, an outreach site, which would 14 essentially operate as a satellite for that core post 15 office? 16 A. Yes, it may have more than one satellite, if you like, 17 but, yes, that's essentially it. 18 Q. In order to operate those satellite sites, the core 19 branch would rem out cash and stock to the outreach 20 site? 21 A. Yes. 22 Q. In this case, what's been described here is a problem 23 where someone would, in this case, rem out £8,000 so 24 that would come out of the core site, so scan that out, 25 go to scan it into the outreach site, but that was 47 1 duplicated -- sorry, it was duplicated several times, so 2 that the outreach site was showing more cash than 3 actually what went across. So in this case, £24,000 4 rather than £8,000. 5 A. Yes. 6 Q. Now, if we go up, please -- sorry, leave it there for 7 the second, sorry. 8 We see at the bottom of that explanation that: 9 "The incident was passed to Fujitsu who have advised 10 that in order to resolve the issue, the branch/NBSC must 11 'complete a rem out for the excess to correct the cash 12 holding' which Fujitsu are unable to do. The NBSC has 13 subsequently advised that they cannot assist as this is 14 an IT issue however Fujitsu are also advising that they 15 cannot assist. As a result, the issue has been passed 16 back and forward for over a week." 17 Obviously, this email is 20 October, the issue was 18 raised on 8 October, some 12 days earlier. Do you 19 consider it's satisfactory for this issue to be bounced 20 between the two teams for 12 days? 21 A. No. 22 Q. Was this is an issue that regularly happened where 23 subpostmasters' complaints such as this fell between the 24 cracks? 25 A. I wouldn't say regularly, no, and I don't know, I think 48 1 this was possibly the first example of this kind of 2 issue that I'd seen. So whether or not, if there'd been 3 any previous ones, at that point I would be wondering 4 what had happened to them beforehand, how, you know, 5 what the cause was, how quickly had they been fixed. 6 What -- you know, what the process was to get it sorted 7 out. 12 days, no, because if I'd been the subpostmaster 8 and I was looking at a discrepancy of £24,000, then I'd 9 have been sweating, for 12 days, when really, if it's 10 a known problem or we can identify what the problem is, 11 it should be easy enough to fix. 12 Q. Is your evidence that this is the first system bug that 13 you were aware of? 14 A. I don't know what you mean by system bug. 15 Q. Or a bug in the software system -- a bug in the 16 software? 17 A. Well, possibly it was, yes. I mean, I don't know 18 whether -- I don't know what the difference is between 19 bugs, glitches and errors, for one. Things that went 20 wrong -- I suppose, when things went wrong, if 21 a communication broke down -- I'd seen those before 22 where they would end up being a discrepancy, but they 23 were always -- you could correct them with fall back and 24 recovery processes. So there would be interruptions to 25 the Horizon System, like there is with your phone or 49 1 anything else, if you like. Except with the Horizon 2 System, obviously, if that was partway through 3 transaction, then it might freeze something and it would 4 then have to be corrected. 5 So I'd seen that type of thing and heard of that 6 type of thing happening before but this was the first 7 time that I'd seen it actually cause a shortage like 8 that where they hadn't really -- there was nothing they 9 could do about it, even under fallback and recovery. 10 Q. We can take that document down and move on to another 11 issue in September 2015, so slightly before. Can we 12 bring up POL00002578 and page 4, please. Just for 13 context, at the bottom is the email from Ibrahim 14 Kizildag to the Branch Support Team about Fleckney Post 15 Office, to which we see above you respond? 16 A. Right. 17 Q. Go down to that email, from Ibrahim Kizildag, please: 18 "I took a manager call from Fleckney Post Office, 19 branch code is [gives a branch code]. This branch had 20 a Data Centre link error message yesterday evening and 21 PM couldn't log on to Horizon System this morning. PM 22 said he had a message stated that they are logged on to 23 another SU [stock unit] they only have 2 positions and 24 nobody is logged in. The PM feels that this is 25 a security issue and he said someone could have log on 50 1 to their system and he is not happy about this message 2 and PM also said he watched Panorama programme and he 3 wants us to escalate this issue. I escalated this issue 4 to Service Desk, if possible can field teams visit this 5 branch regarding this also." 6 Your response is at 4: 7 "The outcome of the call to ATOS is needed before 8 any further action is taken. It might explain what's 9 happened. Is there a ref number? 10 There's a reference to HORice: 11 "Has HORice user data been checked? 12 "For info, this may be raised to you if you're still 13 in contact with Fleckney. 14 "In brief though the recent comms statements should 15 be used and I've no doubt there will be an explanation 16 here that's nothing to do with Horizon." 17 So, again, on what basis did you have no doubt that 18 there was a Horizon issue here? 19 A. Probably because I've ever, ever come across one before 20 and, at that point, I think we could get -- you could 21 get reports on who was logged on to Horizon through 22 HORice, I don't know that we could actually get them 23 anyway. I think there was a user report that you could 24 get off your system and I probably, wrongly, without, 25 you know, knowing all the information and looking at 51 1 what the postmaster could see myself, assumed that they 2 hadn't checked to see who was logged on, where and when. 3 So that's about as much as I can say on that. 4 Q. In respect of the comms statement, in relation to the 5 Panorama documentary, please could we bring up 6 WITN06380102. 7 If we could go to the bottom, please. Just up so we 8 can see the date on the email. So it's Communications 9 Team 14 August 2015, sorry this is below that. From 10 Communications Team, 14 August 2015, to Communications 11 Team, "in the loop -- the latest on Panorama". 12 Go down, it says: 13 "Hello 14 "I wanted to send a short update on the plans by the 15 BBC's Panorama to broadcast a programme about the Post 16 Office and its Horizon System on Monday. 17 "We have spent a great deal of the week dealing with 18 this issue, and making our position clear to the BBC at 19 very senior levels. We do expect, however, that the 20 programme will include a number of unsubstantiated 21 allegations. We have decided against being interviewed 22 as part of the programme and have instead issued 23 a robust statement. This was a very carefully 24 considered decision but the programme wanted us to speak 25 publicly about individual cases and we are not prepared 52 1 to break the confidentiality commitments we have given 2 about these. Whilst it is difficult to take this 3 position in the face of untrue claims being made in 4 public, we believe it is the right one." 5 The next paragraph down says: 6 "On Monday we will be sending out a note to all Post 7 Office colleagues updating them on the programme. In 8 the meantime, our core points are below. I would 9 welcome your help in ensuring that our key messages are 10 cascaded to colleagues, particularly those who may get 11 questions from customers or postmasters ..." 12 The key points: 13 "Extremely serious, unsubstantiated allegations 14 about the Post Office and the Horizon System have 15 continued to be repeated over the past few years by 16 a small number of mainly former postmasters." 17 It goes on below to say: 18 "The clear evidence we have in these cases does not 19 support the allegations being made. 20 "We committed to confidentiality to people who put 21 grievances to us, so we cannot share details about 22 individual cases. 23 "What we can say is that we do not prosecute people 24 for making innocent mistakes and never have ... 25 "We have demonstrated that Horizon works as it 53 1 should. It has been shown to be robust and effective in 2 dealing with six million transactions a day, with some 3 78,000 people using it, and it is regularly audited." 4 I'll leave it there. The rest is in evidence. Was 5 this the messaging you were referring to in that email? 6 A. It will have been, yes. 7 Q. You were relying on that in respect of how you dealt 8 with enquiries that came into you from subpostmasters? 9 A. We would. Everybody would have, not just myself. Yes. 10 MR STEVENS: Thank you, Ms Allaker. I don't have any 11 further questions for now. Some of the Core 12 Participants may do. Before I do, is there anything 13 else you'd like to say to the Inquiry? 14 A. No, there's not. 15 MR STEVENS: I think Mr Stein has a question. 16 Questioned by MR STEIN 17 MR STEIN: Ms Allaker, when Mr Stevens started asking you 18 questions today, he was asking you about your knowledge 19 of the subpostmasters' contract. I'm going to ask you 20 a question about that. My name is Sam Stein -- another 21 Sam -- and I represent a large number of subpostmasters 22 and mistresses. 23 Okay, Mr Stevens referred you to a document which 24 has a Relativity reference of POL00000254. If it is 25 possible, Lawrence, for that to go on the screen, and 54 1 within that document it's page 33 on Relativity 2 pagination. This time please, very top of the page, 3 highlighting "Losses" at paragraph 12, if you could 4 expand that and highlight in yellow I would be very 5 grateful. Thank you very much. 6 So, generally speaking, this is the contractual term 7 that was in place for subpostmasters and mistresses 8 throughout the time of the operation of the Horizon 9 System. It says: 10 "The Subpostmaster is responsible for all losses 11 caused through his own negligence, carelessness or error 12 ..." 13 That's the relevant bit you were asked about 14 earlier. 15 Now, just help us understand a little bit more about 16 what you thought that meant, now meant in terms of who 17 needed to prove negligence, carelessness or error. So 18 there were perhaps two choices. Did the Post Office 19 need to prove that the subpostmaster had been negligent, 20 careless or in error, or was that for the postmaster or 21 mistress to prove that they hadn't? 22 A. Probably a little bit of both. If -- from my 23 interpretation. Because there was a lot of procedures 24 that you were expected to follow from a security point 25 of view, and so there would be, if you were interviewing 55 1 somebody, for example, to say, you know, how did this 2 happen, how -- what are your general procedures in 3 branch? You would try and make sure that what they were 4 doing was following all the necessary security 5 guidelines, so that access to stock and cash was 6 restricted, that things were locked away appropriately. 7 So it was up to us to make sure they knew what they 8 were doing and it was up to them to say, "Yes, that's 9 what we have done". So I think, in a way, to answer 10 your question, a little bit of both. 11 Q. What if the situation was that the subpostmaster 12 couldn't explain, in other words had no idea where the 13 shortfall came from? Now in that situation, they're not 14 saying that they are careless, they're not saying 15 they're negligent, they're not saying they're in error, 16 they're just saying, "I don't know". In that situation, 17 who was it to prove that they had been careless, 18 negligent or in error? 19 A. In that case, in all honesty, I don't think you can 20 prove it one way or another. Because if you've made 21 a mistake, if you've -- if something has happened 22 accidentally or even if someone has taken the money and 23 you don't know anything about it, then in all honesty, 24 you can't prove anything one way or the other. 25 So if you'd dropped the money into a postbag or the 56 1 bin and it had been emptied and gone missing, you don't 2 know that it's carelessness, negligence or what's the 3 last one -- error. So I don't think you can prove it 4 one way or another. 5 Q. In a situation whereby the subpostmaster is saying, 6 "Ms Allaker, I really don't know what's happened here", 7 what would be the position from the Post Office? That 8 would still be down to the postmaster or mistress to 9 make good that loss? 10 A. Yes. Not necessarily all in one lump sum, depending on 11 circumstances, but yes. 12 Q. That was the position that was known and operated 13 throughout the team that you worked in and, indeed, you 14 worked within? 15 A. Yes. 16 MR STEIN: Excuse me one moment. 17 Sir, thank you. 18 SIR WYN WILLIAMS: Anyone else? 19 Thank you very much for making your witness 20 statement and for coming to give evidence to the 21 Inquiry. I'm grateful to you. 22 A. Thank you. 23 SIR WYN WILLIAMS: So no doubt we'll have a short break 24 while we call another witness, so to speak. 25 MR STEVENS: I think we need 20 minutes, sir, if that's 57 1 okay. 2 SIR WYN WILLIAMS: All right, fine. 12.05 pm. 3 MR STEVENS: Thank you, sir. 4 (11.46 am) 5 (A short break) 6 (12.06 pm) 7 MR BLAKE: Thank you, sir. Can we call Gayle Peacock, 8 please. 9 GAYLE PEACOCK (affirmed) 10 Questioned by MR BLAKE 11 MR BLAKE: Thank you very much. Can you give your full name 12 please? 13 A. Gayle Anne Peacock. 14 Q. Thank you, Ms Peacock. In front of you, you have two 15 bundles, I believe. 16 A. Yes. 17 Q. Behind one of them, tab A, you have your witness 18 statement. Can I ask you to turn to your witness 19 statement. 20 A. Yes. 21 Q. Is that statement in front of you dated 31 January of 22 this year? 23 A. It is, yes. 24 Q. Can I ask you to look at the final page, final 25 substantive page, at page 50. Is that your signature at 58 1 the bottom? 2 A. Yes, it is. 3 Q. Is that statement true to the best of your knowledge and 4 belief? 5 A. It is. 6 Q. Thank you very much. That witness statement is going to 7 go into evidence and it will be published by the 8 Inquiry. For the purpose of the transcript it's 9 WITN06160100 and the questions I'm going to ask you 10 today are going to be supplementary to that and we will 11 expand on a few areas. I am going to start, though, on 12 your background, which you have detailed in the 13 statement. I just -- you've been in quite a large 14 number of different areas, a number of different roles, 15 so I'm going to focus on the ones that are relevant for 16 today's purpose. 17 A. Okay. 18 Q. You joined the Post Office in 2001 as part of a graduate 19 management trainee scheme; is that right? 20 A. It's correct, yes. 21 Q. During that scheme, you used Horizon, I think, when you 22 were seconded to Middlesbrough Post Office? 23 A. I did, yes. 24 Q. You subsequently held number of positions. I'm going to 25 start with 2006 to 2010, you were the head of network 59 1 co-ordination. Can you briefly tell us what that 2 involved? 3 A. So there was two aspects to the role, really. One was 4 around -- they'd set up the outlet intervention team in 5 Maidstone, so this was the escalation point for 6 subpostmaster queries, where they couldn't get the 7 answer from Network Business Support Centre, anything 8 that couldn't be answered by the helpline, we had to set 9 that team up to basically deal with those enquiries, so 10 there was that part of the team I managed. 11 I also managed a team of network co-ordination 12 managers and they interacted mostly with the heads of 13 area and their Retail Line managers to understand some 14 of the issues that branches were facing, whether that be 15 cash management, product and branch accounting, and 16 tried to sort of help postmasters, really. 17 Q. Then between 2011 and 2013, you were network conformance 18 standards and policy manager. Can you tell us briefly 19 what that involved? 20 A. Yes, so that was -- there was a branch standards booklet 21 published, I think, in 2009 and this was basically 22 running the team that would help branches understand how 23 to follow the correct procedures. So I had a team of 24 people that would make telephone interventions to 25 branches, and to talk them about the areas within the 60 1 booklet. I also had a data team that would look at the 2 results of the different areas, plan the sort of support 3 roles, the intervention the telephone calls. 4 I had a mails support manager who worked for me, 5 I think, at the time and that was around managing some 6 elements of the Mails Distribution Agreement or some of 7 the complex issues that we had with Royal Mail to 8 resolve. Then I had a multiples service manager and 9 they were responsible for all the conformance elements 10 with the likes of McColls, Co-op, interfacing with those 11 partner groups, really, to drive performance in the 12 areas that we were focusing on with post offices. 13 Q. Thank you. 2013 to 2014, head of branch support 14 project. Briefly -- we'll go into it in more detail -- 15 but can you tell us what that involved? 16 A. Yeah, so I was asked to lead the project on the back of 17 the Second Sight review and some of the issues that were 18 coming -- the thematic issues that were part of that 19 review, to really understand what we could do to help 20 postmasters, especially in the likes of training and 21 support, and what we could do differently. So it was 22 really about doing more of a deep dive into some of the 23 themes that were coming out of those spot reviews and 24 the individual cases, and then looking across the 25 business to say "Well, how could we improve things, what 61 1 would we need to put in place". That kind of thing, 2 really. 3 Q. Finally, between 2015 and 2018 you were head of branch 4 and customer support. 5 A. Yeah. 6 Q. Now, that was what previously we know as the NBSC; is 7 that right? 8 A. It was, yes. Yes, that's correct. 9 Q. You were involved in a number of matters in that role 10 but one of them included managing executive 11 correspondence? 12 A. Yes, so that was anybody, it was Members of Parliament, 13 public, postmasters, who would write to the Chief Exec 14 or any member of the Post Office executive team. So it 15 was that team who would get those complaints and manage 16 them, basically, in the business. 17 Q. It sounds as though, in broad terms, a lot of your 18 career has focused on support to subpostmasters, whether 19 it be providing that directly or reviewing the support 20 that's provided to subpostmasters; is that a fair 21 description? 22 A. Yes, that's correct, yes. 23 Q. Are there any other roles that you held that I have to 24 failed to mention that you think are relevant to this 25 Inquiry? 62 1 A. Um, I don't think so. I mean, I did a Retail Line 2 Manager role where it was, you know, I was looking after 3 a patch of branches myself, in my early part of my 4 career but I guess that's probably not really relevant 5 to the themes out of the Horizon Inquiry as such. 6 Q. We've heard earlier in this phase about the training 7 that was provided at rollout and it was only a day and 8 a half. 9 A. Yes. 10 Q. By 2006, in broad terms, what kind of a training package 11 was offered to subpostmasters? 12 A. It was a colleague in network services, and I think it 13 was split at the time as Andy Bayfield and Julia Marwood 14 who managed the team. So I think, in terms of the broad 15 level detail, I think at 2006, I think it was a week's 16 classroom course that they were offered, a transfer 17 balance, which was obviously the incoming and the 18 outgoing postmaster, and then, depending on the size of 19 the branch there could be like five days face-to-face 20 support in branch. And then I think there was 21 a follow-up balance so that the next time the branch 22 needed to do their cash account or branch trading they 23 would attend, and then I think I believe there was what 24 we called post-transfer visits or -- I think it was one, 25 three and six months. I think that was what was on 63 1 offer at the time. 2 Q. Thank you. So the amount of training certainly had 3 increased since rollout. You say in your statement that 4 the overall training to postmasters needed to be 5 improved. Can you expand on that a little bit? 6 A. I think generally it was -- the difficulty you got with 7 a network that size is the volume of postmasters and the 8 one size fits all. So you've got your challenge of 9 geography, you had people who couldn't attend the 10 classroom course for whatever reason, you know, Post 11 Office didn't pay for a postmaster to actually come and 12 attend them, sometimes the timing wasn't convenient of 13 the training and then you obviously had the different 14 product mix as well, and then sometimes there would be 15 challenges potentially if you went into a branch and the 16 postmaster wasn't present or you would train staff. 17 So -- and the other thing is you could be giving 18 training to a postmaster but you would only cover the 19 things that were available during that five days. So if 20 a transaction wasn't there, for example because it 21 didn't happen very often, it wasn't covered because you 22 didn't have the opportunity to do it, because you might 23 teach the theory but not the actual practice. 24 So, yeah, I think one of the challenges, I don't 25 think we understood the effectiveness of the training. 64 1 You know, it was like that was what you got and that was 2 it. You know, I don't think there was any kind of 3 training needs assessment with postmasters to go "Do you 4 learn by computers, do you -- are you practical?" You 5 know, there just wasn't the opportunity for that 6 flexibility. There was no online learning packages at 7 that time either, it was literally face-to-face or 8 classroom and that was it. So it probably fell down in 9 a number of ways. 10 Q. Can you assist us with the difference in training that 11 was provided to Post Office employees versus 12 subpostmasters? 13 A. I think that was managed by central HR teams. When 14 I joined, I got a two-week counter training classroom 15 course that I attended and then obviously that would 16 have followed up in branch. I don't think there was any 17 kind of formal induction programme for Post Office 18 employees. When you mean "employees", do you mean like 19 directly managed staff or do you mean the likes of the 20 corporate staff like myself? 21 Q. I think somewhere in your statement you say, 22 effectively, that the training that was provided to 23 employees was better than that to subpostmasters, the 24 quality and training was better. 25 A. Um ... can you point me to where you interpreted that? 65 1 Q. It's in the statement at different points. It's not a 2 secret. If you don't agree with it then that's 3 absolutely fine as well. 4 A. Yeah, I probably disagree with it, actually, because 5 I think it was, you know, I think one of the 6 observations is that sometimes, you know, Post Office 7 employees or colleagues didn't understand what it was 8 like to be in a branch network because they weren't 9 exposed to the Horizon terminal, the likes that I had. 10 So it was quite inconsistent and hit and miss so, yeah, 11 that's not the message I wanted to convey in the 12 statement, if that's what you were implying. 13 Q. You do say in your statement that if there was space, 14 managers and assistants could attend? 15 A. Yeah. 16 Q. Are you aware of there not being space in certain 17 circumstances? 18 A. I can't recall any. I think it was about six to eight 19 places, potentially available. I don't know if anybody 20 was tracking, you know, what the take-up was. 21 Q. In 2006, you were head of network co-ordination -- 22 A. Yes. 23 Q. -- and we'd spoken about that. There was a business 24 reorganisation in 2006. 25 A. Yes. 66 1 Q. Can you tell us how that affected the issues that we're 2 discussing today? So in terms of the offices, you've 3 said there were area offices prior to that? 4 A. Yeah, so in 2006, I think it was McKinsey's that did 5 a big -- it was a full business restructure and 6 everybody, I think, bar a very small portion of 7 colleagues went through what we call a preference 8 exercise. So they were asked, you know, did you want 9 a job with the business, did you want to take redundancy 10 or whatever. So everybody was asked and then one of the 11 big changes they made in 2006 was, prior to that time, 12 regardless of what size branch you were, where you were 13 located or whatever, you had an area manager tagged to 14 you, and there was a sales and service structure 15 immediately prior to that in 2006. 16 So one of the big changes of the 2006 restructure 17 was the decision was made that a large portion of the 18 network wouldn't actually have an area manager tagged to 19 them as a branch and that any enquiry that they had 20 would be tagged to the Network Business Support Centre. 21 So I think it was about 2,000 branches that were given, 22 like -- in effect, it was a sales type manager. So they 23 weren't really supposed to do what we would call the 24 service elements or, you know, the transactional 25 queries, that kind of thing. And then literally 67 1 everybody else was -- that was the decision that was 2 made, was you would be directed to the Network Business 3 Support Centre. 4 There was about 11 area offices as part of that 5 sales and service structure that was closed. So they 6 all closed and it was left with Maidstone. So one of 7 the jobs that I was tasked with doing was someone in my 8 team was closing all of those area offices, which 9 included things like branch files, we had to relocate 10 them to Leeds and then, obviously, all of those members 11 of staff, they went and everything was closed, and it 12 literally left Maidstone. 13 Q. Prior to that reorganisation, if there was a service 14 problem you would have somebody who could physically 15 attend the branch? 16 A. Yes, so there was a series of, I think, either area 17 intervention managers or area performance managers. 18 I can't remember the exact structure because I didn't 19 work in it but I knew, obviously, colleagues who did. 20 Yeah, they would manage all of what we'd call the 21 non-sales issues, so things like problems balancing, 22 losses, robbery/burglary, relocations, anything like 23 that, then it would be directed to the regional teams, 24 and they would then have a plan for how to support the 25 postmasters within their region. 68 1 Q. How did the change impact on that? Say you had 2 a problem with balancing. Was that no longer available? 3 A. So there wasn't necessarily a person to go to, so the 4 route -- one of the things that we had to do when we set 5 up the team in Maidstone was actually understand what 6 all of the processes were that were affected and then 7 decide who was left in the business to pick that piece 8 up and then almost redesign that process. If the 9 Network Business Support Centre couldn't deal with it 10 then that's when it came into the outlet intervention 11 team in Maidstone, which I managed and then we would 12 work with the relevant teams to try to sort something 13 out. 14 So with the balancing enquiry, if they couldn't 15 resolve it, we would do our own investigation in terms 16 of going through the possibilities that it could be, we 17 would possibly liaise with Product and Branch Accounting 18 to see if there's any other information that would be 19 available and, worst-case scenario, we would send 20 somebody out to from what we would call the field team, 21 so a trainer or auditor, to see what could actually be 22 done to help the postmaster. 23 Q. When was that? Was that 2006 or -- 24 A. That was 2006. 25 Q. At paragraph 66 of your statement, you say that 69 1 replacing physical support with remote intervention was 2 not enough for some subpostmasters. 3 A. I don't think it was. You know. It assumed that 4 everybody could cope and everyone was at the same level 5 of, you know, competence, I guess, or, you know, if you 6 he had a new subpostmaster, possibly the ones that had 7 been there quite some time were probably okay because 8 they knew how to do things. I don't think the business 9 knew how people would be affected and didn't tailor that 10 support in accordingly. It was just assumed that 11 everybody could manage on their own. 12 Q. Do you know what the driver was behind the 13 reorganisation? 14 A. I wasn't party to those conversations. I'm making the 15 assumption it was probably cost. You know, there was 16 a big drive that we had to get back to profit as 17 an organisation, the sort of government income from 18 pensions and allowances, the branches were migrating 19 onto card account. You know, in terms of the income 20 that was available to postmasters and Post Office, it 21 was just what -- I think it was a cost commercial 22 decision to do that. 23 They couldn't see the commercial return on having 24 a physical body going out to a branch and supporting 25 them. They couldn't translate that into a monetised 70 1 value. 2 Q. I think you mentioned there were 2,000 or so branches 3 which had a different level of service? 4 A. Yes. 5 Q. Were those the more commercial branches? 6 A. Yeah, so the bigger branches. You know, the ones that 7 might have the potential to -- because at that time 8 there was sort of the drive to increase Financial 9 Services, so we were moving into car insurance, home 10 insurance, all of those kinds of things and it was felt 11 that actually that those branches had the right 12 demographic, they had the right footfall, they were 13 bigger in remuneration and, therefore, they deserved 14 more support than the smaller ones. 15 Q. You've said that introducing the pre-2006 position or 16 reintroducing that was not a commercially viable option. 17 Can you expand on that? 18 A. So I think -- I mean, the background to the branch 19 standards booklet was, I think, you know, in about 2007, 20 they were starting to feel some of the consequences of 21 not having that, you know, immediate support for the 22 branch, and I think and it was just too expensive to 23 re-introduce a physical presence and I think the 24 preferred option was see what you can do remotely from 25 an outbound perspective before you then start 71 1 introducing area managers back in. I don't think that 2 was an option for us to consider. 3 Q. I think you also said in your statement that resourcing 4 over the phone support was the best, given the financial 5 circumstances? 6 A. Yes. 7 Q. Do you know who within the company was driving this 8 move? 9 A. I think it was just a top-down -- you know, it was at 10 board level. So I think one of the strategies, I think 11 it was the Forward 5 to 11 that was launched on the back 12 of -- there was the big business restructure, it was, 13 you know, back to profit was the 2006 Forward 5 to 11 14 strategic -- you know, you did Forward 5 to 11 and then 15 the 4 to 11 and then the 3 to 11, so it was very much 16 front and centre driven from the top that actually that 17 was the business strategy that Post Office was going to 18 deploy. 19 Q. You've said there was no central system to understand 20 who had visited which branches -- 21 A. No. 22 Q. -- and that some that never been visited or may never 23 have been visited; is that right? 24 A. Yes. 25 Q. Yes. Did that change or is there now a central system? 72 1 A. Yeah, so I think over time it definitely did. One of 2 the criticisms is obviously the Second Sight report was 3 obviously there was no central point for recording 4 contact. One of the things that I was involved in 2017 5 was the introduction of Microsoft Dynamics CRM solution 6 which recorded who was making outbound or receiving 7 inbound interventions from branches so that was rolled 8 across like 25 different teams across Product and Branch 9 Accounting, NBSC, Security, a number of different back 10 office teams, HR, so we could at least track who was 11 having a conversation with who about what. 12 They then made that into, I think, the branch 13 information tool, which was made available to area 14 managers, so they could at least understand what their 15 branches were, what conversations they were having with 16 certain branches. I don't think they ever got to the 17 position of, like, physically tracking who was going in 18 and, you know, like you could have a security manager 19 visit one day and an area manager the next. I don't 20 think they ever implemented that. They may have done 21 since I've left. I'm not sure. 22 Q. You said at paragraph 25 of your statement and I think 23 you've repeated it in your evidence today, that 24 postmasters could request further support from the NBSC? 25 A. Yes. 73 1 Q. That's from the 2006 reorganisation. 2 A. Mm-hm. 3 Q. Were you aware that in 2010, the Post Office was going 4 to start charging for visits to the branch? 5 A. Yes, it was. So that was part of the branch standards 6 change that I was involved in implementing. So it was 7 a contractual change with the postmasters and I think 8 there was -- I think there was a charge specifically 9 related to cash holdings, so this was where, if 10 a postmaster failed to regularly declare the cash in 11 branch correctly and, despite any sort of help, 12 intervention and support repeatedly needed to do it, and 13 then somebody had to go out, there was the mechanism in 14 the contract to charge for it if it was deemed 15 appropriate to charge for it. 16 I think the other one in there was the regulatory 17 compliance training. So the post offices had to do 18 I think it was about 12 modules every year and there 19 were a handful of branches that repeatedly failed to do 20 that training, despite your phone calls, help, so it was 21 seen as a last resort for a minority of branches. 22 I can't remember the volume that were involved but 23 we had possibly a handful, every now and again, that 24 were subject to this -- to the charge. But given the 25 volume of telephone interventions the compliance 74 1 training generated usually about 1,000 calls every month 2 to branches to remind them to do it, and then you might 3 potentially be left with two or three who just may have 4 refused, or didn't do it for whatever reason. In that 5 instance, the postmaster would have been advised 6 beforehand that, you know, "You've got the option to do 7 it, if we need to send somebody out, there is the option 8 that we can charge it". And I think there was a cap on 9 the charge, as well, that it would only be up to 10 a certain amount of money. It was intended to cover the 11 cost of the person that would go out to help. 12 Q. Can you tell us briefly what was branch standards? It's 13 a booklet or something else? 14 A. So the branch standards -- well, it was a booklet in the 15 team so the branch standards was there to define what 16 the business as a whole deemed to be the important sort 17 of standards that a branch should follow. So there was 18 the booklet and the communication and then there was my 19 team, the branch standards team, that would -- we used 20 to send out the scorecard to branches every month to say 21 this is how your performance -- how you're doing against 22 the standards. And then we would make the relevant 23 support interventions as well to branches who we felt 24 needed some help understanding what some of those 25 procedures were. 75 1 Q. I'm going to take you to a document can we look at 2 POL00084464. So you will be familiar with this 3 document. 4 A. Yes. 5 Q. It says: 6 "Dear colleague, 7 "I'm pleased to send you the Post Office Branch 8 Standards booklet." 9 So this document and the booklet would go to the 10 Post Office branches? 11 A. Yeah, so there was a covering letter, there was a copy 12 of the booklet, because it was a contractual change they 13 would have received a copy of the contractual amendment 14 as well. Yeah, it would have been part of a pack. 15 Q. Can we scroll down on this page to the paragraph that 16 says, "Starting in June 2010", thank you. It says: 17 "Starting in June 2010, we will pass on to you the 18 cost of any visits to your branch to ensure that 19 compliance training has been completed. We will also 20 pass on the cost of any further training if you are not 21 carrying out your overnight cash or ATM declarations 22 properly, including the cost of visiting your branch to 23 deliver the training. We will also pass on to you the 24 charges we have to pay for missing motor vehicle licence 25 ... discs. The details of how these measures could 76 1 affect you are shown in the 'Conformance with the branch 2 standards' booklet included with this letter." 3 Do you think at this time there was a hardening of 4 attitudes towards postmasters in trying to charge them 5 for services that had previously not been charged for, 6 for example? 7 A. Um, I'm not sure, really. I think there was probably 8 some discussions around what else we could do, so you 9 would try and help branches as much as you can but 10 you -- sometimes you were just left with a group that 11 just for whatever reason, didn't do what everybody else 12 wanted to do. So I think it was almost -- well, would 13 this sort of act as a motivation if people thought 14 financially they might be impacted by it? Would it, you 15 know, would it make any difference? I'm not sure 16 generally whether a hardening attitude towards 17 postmasters, I don't think. 18 Q. Well, let's say if a subpostmaster had a shortfall that 19 they couldn't explain, we've heard that they'd have to 20 pay for the shortfall? 21 A. Yeah. 22 Q. But now would they also pay for additional support if 23 somebody was required to come and visit them? Would 24 they have to pay? 25 A. If you wanted to enforce the contract, then yes. 77 1 Q. We've heard also from some witnesses that the training 2 that had been provided to subpostmasters contained some 3 gaps when it came to things like balancing. 4 A. Right. 5 Q. Would you agree with that? 6 A. I would, yes. 7 Q. If you needed more training to cover that, would you 8 have to pay for that? Would that be -- require a visit 9 that you'd have to pay for, potentially? 10 A. No, you wouldn't have to pay for those ones. 11 Q. Are you aware at this time of continued financial 12 difficulties within the Post Office, so 2010? We spoke 13 about 2006 and the reorganisation. 14 A. Do you mean postmasters or Post Office? 15 Q. No, the company, Post Office. 16 A. In what respect? 17 Q. Were there financial pressures still. You spoke about 18 them in 2006. Did those continue in 2010? 19 A. I think there was always a focus on cost with Post 20 Office, you know, throughout the whole of my career. 21 There was always the emphasis to do things more 22 efficiently, you know, it's a government funded 23 organisation. It was reduced to tax -- the burden on 24 the taxpayer. What could you do? And it was constantly 25 in the culture that what could you do to reduce costs? 78 1 That was just -- you know, that was just part of what it 2 was every year when we had teams. The budget got, just 3 got reduced, and you would have to find a way to manage 4 that. We had numerous reorgs and most of that was 5 driven of what could you do better, what could you stop 6 doing? What could you reduce? 7 So I think the focus on cost because, you know, it 8 was a commercial organisation that was paid for by the 9 taxpayer, there was that constant need to actually just 10 keep -- you know, reduce it, reduce it, reduce it. 11 Q. Can we look at POL00084769. This the "Branch Standards" 12 document? 13 A. Yes. 14 Q. Is that what would have been attached to that document 15 that -- 16 A. Yes, it was a small A5 booklet, yes. 17 Q. Thank you. If we turn over the page, you have 18 an introduction and that introduction is from Paula 19 Vennells, the network director at that stage? 20 A. Yes. 21 Q. Was she responsible or was she the driving force behind 22 this branch standards document and the change in 23 approach? 24 A. Yes, so this was the initiative. So the branch 25 standards were part of the network efficiency programme 79 1 that was set up, that was ultimately sponsored by Paula, 2 I worked to Lynn Hobbs, Lynn Hobbs worked to Paula and, 3 you know, this was the direction that was given. It was 4 we need to try to find a co-ordinated approach of 5 importing standards with the network. So yeah, Paula 6 was completely aware of what we were doing. She would 7 have had to have signed off this opening introduction as 8 well. 9 Q. So it was enforcing standards, but it was also, at the 10 same time, trying to meet the cost pressures that the 11 Post Office was under? 12 A. Yes. 13 Q. Can we look at page 15, please. Thank you. There's 14 a section there on "Processing transactions correctly", 15 on the right-hand side, and I'll read it. It says: 16 "Rectifying mistakes is a significant cost to the 17 Post Office. Whilst we understand that mistakes will 18 happen on occasion, we want to minimise them -- to 19 reduce our costs and give good customer service. 20 Getting transactions right means that we don't have to 21 waste time resolving mistakes. It also gives our 22 partners confidence that we can transact their products 23 in the correct way". 24 There are suggestions there for "Getting it right 25 every time": 80 1 "Make sure that you and your teams follow the 2 correct procedures for each transaction. This will 3 increase confidence and help prevent transaction errors 4 and corrections. 5 "If you receive a transaction correction to rectify 6 a mistake, deal with it as soon as possible, and always 7 within the balance trading period. 8 "If a transaction correction has a monetary value, 9 any discrepancies must be dealt with promptly by 10 contacting Product & Branch Accounting." 11 At this period in time, was there a particular focus 12 on mistakes being the fault of the subpostmaster or 13 certainly a belief that the mistakes that were occurring 14 were the fault of the subpostmaster? 15 A. I think there was a focus on cost so the view was, you 16 know, you've got people in Product and Branch Accounting 17 in Chesterfield who are literally there because they're 18 sending things backwards and forwards to clients because 19 something has happened in branch. I think there was 20 that. 21 I think there was also an awareness that some of our 22 transactions weren't as easy to follow as they could 23 have been. Yeah. 24 Q. Were subpostmasters seen as the cause of some 25 unnecessary costs that were impacting the Post Office? 81 1 A. I think probably somewhere but then I think also there 2 was the view that some transactions were potentially 3 difficult. I think it was probably a combination. 4 Q. What do you mean by "difficult"? 5 A. So, you know, throughout the some of the evidence 6 obviously things like scratchcards, reversals, that kind 7 of thing. I think, you know, a lot of the information 8 within the bundle sort of alludes to the fact that some 9 of this stuff wasn't as ease as it could have been in 10 terms of the product process. 11 Q. How was this assisting, telling subpostmasters to just 12 get it right, to follow the correct procedures? 13 A. I mean, in hindsight it's probably not, is it? 14 Q. I'm going to move on to another document that I think 15 accompanied the branch standards. Let's look at 16 POL00084774. I'm just going to read to you that first 17 paragraph or some of the first paragraph. 18 Can you just tell us briefly, though, was the 19 document that went alongside -- 20 A. Yes. 21 Q. -- it was to be read along -- 22 A. It would have been like Q&As gone out with it, yes. 23 Q. "What type of consequences will there be for not 24 complying with branch standards, including selected 25 standards? 82 1 "There will be specific financial consequences for 2 subpostmasters who do not meet the expected level of 3 performance for some branch standards. The amendment to 4 the subpostmaster contract which introduces the 5 financial consequences is also included with the 6 information that will be sent with the booklet." 7 So again, my reading is that there's a hardening 8 towards the subpostmasters of attitude; is that wrong? 9 A. I don't really -- yeah, I can't really give an opinion 10 on that. What from 2006 to 2010 or a specific time 11 period? 12 Q. Well, in 2010 you had these branch standards and 13 subpostmasters are being threatened with specific 14 financial consequences. Do you agree that that it has 15 that kind of a tone about it or not? 16 A. Yeah, it does have a tone about it. I don't know 17 whether that changed significantly from 2006 or there 18 was a step change. I'm not sure. 19 Q. I mean, we see there, for example, the fourth bullet 20 point: 21 "If branches fail to complete cash declarations, 22 including those relating to ATMs, and performance 23 doesn't improve following remote intervention, a member 24 of the Network Support Field Team will visit the branch 25 to conduct further training, which will be at the cost 83 1 of the subpostmaster." 2 Scrolling down: 3 "The existing contractual consequences for poor 4 application of branch standards remain. This includes 5 the possibility of action being taken under the 6 subpostmaster contract. This could be corrective action 7 with a possibility of contract termination, and/or 8 removal of a product from the branch. If 9 a subpostmaster has a query relating to specific areas 10 of their contract then this query should be raised with 11 the Human Resources Service Centre. Certain breaches of 12 branch standards which involve regulatory bodies may 13 instigate criminal [proceedings]." 14 In this question and answer document, is there, for 15 example, any mention of how a subpostmaster might 16 dispute a transaction correction? 17 A. Within this one or the branch standards one? 18 Q. Yes. 19 A. I can't recall, to be honest, Julian. 20 Q. How about disputing discrepancy in their figures and 21 their branch trading statement? Were those kind of 22 things addressed in either the branch standards document 23 or the accompanying Q&A? 24 A. I don't think so. I think there was an agent support 25 charter, I think -- I can't remember the time when that 84 1 came out. I don't know if that was before or after the 2 branch standards booklet and that was around the service 3 level agreements that Post Office would provide to 4 postmasters. I think that covered it but I can't 5 remember when that was produced. 6 Q. Just while we're on this document, if we scroll down to 7 page 3, the final page: 8 "Will new subpostmasters be subject to the same 9 standards and consequences? 10 "Regardless of how long someone has been 11 a subpostmaster, we expect them to achieve the branch 12 standards." 13 The final sentence there: 14 "Also, any branch losses will be the responsibility 15 of the subpostmaster from the day of taking over the 16 branch." 17 Was it assumed during this period that, if there 18 were losses, they were caused by user error rather than 19 any fault with the Horizon System? 20 A. Yeah, I think that was just a widespread Post Office 21 assumption, that it was due to what they would call 22 "branch non-conformance" or "user error". 23 Q. Thank you. Thank you. I'm going to move on to 24 a different topic and that's suspension and appeals. 25 You've explained that at one point you attended 85 1 audits. I think you were shadowing or something along 2 those lines. 3 A. Yes. 4 Q. Can you briefly tell us in what capacity that was in? 5 A. It was just as a learning exercise, so just to find out 6 what actually happened, what it would involve. So 7 I just attended the branch audit to actually see what 8 happened. 9 Q. Did you come across any auditors who were not acting 10 professionally? 11 A. No, not in my experience. 12 Q. Are you subsequently aware of any unprofessional conduct 13 by auditors? 14 A. I think -- I can't remember specific examples but 15 I think, obviously, there were some concerns raised, you 16 know, as part of the Inquiry. But I can't remember the 17 specific ones. I didn't have any raised individually to 18 me. 19 Q. When you say "Inquiry" do you mean this Inquiry or -- 20 A. This Inquiry, yes. 21 Q. Were you involved in appeals against termination? 22 A. I was, yes. 23 Q. What role were you -- 24 A. I was the appeals manager. 25 Q. Can you tell us how those took place, what format they 86 1 were? 2 A. So there was a group of people who were selected to be 3 appeals manager. I was one of those. The contracts 4 manager would manage the contractual proceedings or 5 processes with the postmaster. They would make 6 a decision in terms of whether the contract needed to be 7 terminated and on what grounds, relating to the specific 8 part of the contract. The postmaster was then given the 9 opportunity to appeal that decision and then I think 10 they submitted their request to the HR service centre, 11 and then they would be just an appeal manager allocated 12 to that particular case and I was one of those managers 13 that was selected if a postmaster want to actually 14 appeal. 15 I would then receive the appeal papers relating to 16 that case. So that would be a bundle from the contracts 17 adviser or contracts manager who'd dealt with that case, 18 any information that was relevant to how that decision 19 had been made, any kind of meeting notes, that kind of 20 thing. I would then contact the postmaster and arrange 21 to meet them and they'd have the opportunity to sort of 22 like have that discussion with me, present any new 23 evidence. I'd review the case in terms of what was the 24 evidence provided? Was the decision appropriate? Had 25 the case been handled correctly? And then, ultimately, 87 1 make the decision around whether it was appropriate to 2 terminate that postmaster's contract. 3 Q. What period of time are we talking now? 4 A. So that would have been from, I think -- because I think 5 you could only do it when you were classed as a senior 6 manager, so I think it was from 2006 onwards. I think 7 my last postmaster appeal probably would have been about 8 2018. 9 There was a period where we didn't do them because 10 there was a decision made -- I can't remember what time 11 scale it was, but the -- there was -- as part of one of 12 the business reorganisations, there was a dedicated 13 appeals manager that, rather than try and farm them out 14 to individual senior managers across the business, there 15 was a gentleman called Andy Bayfield who managed or who 16 heard all of the appeals regardless of geography. And 17 then I think that -- I think Andy left in about 2010 and 18 then reverted back to individuals across the business. 19 Q. I think you said in your witness statement that in the 20 majority cases there was a financial discrepancy that 21 had occurred, that was a contributing factor. 22 A. Yes. 23 Q. Were subpostmasters represented at these appeals? 24 A. Yes, so they had the opportunity -- so part of the 25 appeals process is they could bring a friend or 88 1 a colleague or a member of the National Federation of 2 SubPostmasters. I think everyone bar one that I ever 3 did was always with two people. 4 Q. Not legal representatives, though? 5 A. No. 6 Q. No. What was your understanding of how easy it was to 7 obtain what we know as ARQ files? 8 A. So these are the files from Fujitsu. So my 9 understanding was that Post Office as an organisation 10 were allowed so many ARQ files, sort of, per year. 11 I think the number was about 300 or 400 or whatever. 12 That was managed by the security investigations team. 13 I think if you needed access to one for whatever reason, 14 you could request it through of the security 15 investigations team. I don't think they were made 16 available as a matter of course. You know, for each 17 suspension case. 18 Q. I think you've mentioned in your statement a few 19 different types of logs. You've talked about 20 transaction logs, keystroke logs and ARQ logs. 21 A. Yes. 22 Q. Do you know the difference between them? 23 A. I think the ARQ was almost the keystroke log, so that 24 would record everything in terms of what the user in 25 branch had, you know, allegedly pressed. The 89 1 transaction log was the log that would be generated from 2 Horizon. So I think anybody with manager access -- and 3 it was -- it didn't have everything, so it was like the 4 transaction stamp of the day. You could run 5 a particular time period, so if you had a discrepancy 6 that you could move the transaction log and then print 7 one in branch. 8 So the transaction log was actually in branch; the 9 ARQ and the keystroke stuff was the bits that were 10 provided by Fujitsu. 11 Q. For the ARQ and the keystroke, would you have to go 12 through the security team -- 13 A. Yes, you would. 14 Q. -- is that something -- 15 A. Yes, you would. 16 Q. Can you describe the difficulties in obtaining that 17 information? 18 A. I never experienced any. I can't remember instances 19 where I would. I didn't know if anybody had been 20 refused, obviously until I read the additional bundles 21 that you sent through for the Inquiry. 22 Q. As part of the appeals process, though, are you aware of 23 ARQ data being requested, being used, in the appeal? 24 A. I would have used, if it was part of the bundle of 25 papers. If -- depending on what the postmaster had said 90 1 at the appeals interview, if I felt that I needed access 2 to that information, I could make that request. I think 3 it would depend on the timescale involved as well, and 4 whether it was still available, but I knew who to go to 5 if I needed one. I couldn't answer for the other 6 appeals managers. I don't know if they knew that they 7 could get one. I knew I could get one but I didn't know 8 if they could. 9 Q. Who would you get it from? 10 A. So it would have been -- well, whoever was running the 11 security investigations team so there was number of 12 people that I would have known to make contact, head of 13 security, who ever was fulfilling that role at the time. 14 Q. Who prepared the appeals bundle for you? 15 A. It usually got sent by the contracts manager so they 16 would be -- it would be bundled up as a file. I think 17 you could get a hard copy file as well, so there was 18 an admin team in Leeds who would post whatever hard copy 19 information you needed to your house or there was 20 an electronic copy as well. 21 Q. If the basis of the termination was a financial 22 discrepancy, would ARQ data be provided ordinarily or is 23 that -- 24 A. I don't think it was a standard process. I don't think 25 it was something that -- like as part of a checklist 91 1 that you would do. I don't think it was -- I don't 2 think it was something that was always included. 3 Q. Was it sometimes included, rarely included, often 4 included? 5 A. Um, sometimes, I think, from recollection. 6 Q. Do you recall any subpostmasters wanting additional data 7 and not being able to receive it? 8 A. Um, I can't recall anybody saying to me that they didn't 9 get it. What I used to do was, you know, print 10 everything off and send it to them that I was going to 11 consider, that -- in advance of that meeting, so that 12 they could see it, so that we could discuss it and then, 13 should anything come across as part of that meeting that 14 you might want to go and look at, so whether you needed 15 access to any remittance slips or anything like that, if 16 there was any information that came subsequently, the 17 postmaster would get hold of it. I think the challenge 18 was if they didn't know what they could have, would they 19 know to ask, necessarily. 20 Q. Do you recall there being information provided to 21 subpostmasters about the availability of that kind of 22 data? 23 A. No. 24 MR BLAKE: Briefly before -- sir, I was woefully optimistic 25 as usual, so we will certainly go over after lunch. 92 1 SIR WYN WILLIAMS: We'll take a normal lunch. 2 MR BLAKE: We'll take a normal lunch break but I'll just ask 3 you a few questions before we break to lunch and that 4 relates to HORice. 5 A. Yes. 6 Q. We heard a little bit about that this morning. I think 7 that stood for Horizon Information Centre; is that 8 right? 9 A. Yes, that's correct. 10 Q. When was HORice introduced? 11 A. So that would have been part of the Branch Support 12 Programme, so that was -- I think it was towards the 13 tail end of 2014. Yeah, I went on maternity leave in 14 October 2014 and I think it was just starting to be -- 15 we were getting towards the end of that particular 16 project. So it would have been not long after that. 17 Q. How did that differ to what was available before? 18 A. So the main difference with HORice, so if a postmaster 19 rang up and said they had problems balancing or they 20 didn't know what had gone wrong, or X, Y and Z, it was 21 really difficult for anybody at the end of that phone to 22 actually understand what had been pressed. It was 23 almost like the adviser was working blind and it relied 24 on the postmaster relaying that information. 25 What HORice enabled a certain number of users to do, 93 1 it was, in essence, the ARQ data within like I think it 2 was like a 15-minute window. So by making that 3 available, you could actually understand if the 4 postmaster had served in the wrong stock unit or logged 5 off or not done, like, a fallback and recovery process 6 correctly. 7 More Post Office users had access to, in effect, 8 what was the ARQ data and could see and try and use that 9 data to help try and work out what had happened in that 10 branch to try to rectify any errors or mistakes. 11 Q. So that information was available to the subpostmaster 12 or assistant? 13 A. We would provide it if it was requested. HORice was the 14 system that was used internally, so it was 15 a licence-based system that I think it started off 16 small, so there was identified users within the Network 17 Business Support Centre, Cash Management, Product and 18 Branch Accounting and the Security Investigations Team 19 as well. 20 Q. Did you still have to go through the security team to 21 obtain the information? 22 A. No, as I say, it was about widening that up with 23 a limited number of users but in like a controlled 24 environment because, obviously, there was sensitive, you 25 know, information in there. So you had to understand 94 1 who was using it, and for what purpose. But there 2 wasn't -- you know, if a postmaster saw, for example, 3 when they contacted the Network Business Support Centre 4 and the person helping them -- because it was usually 5 like a tier 2 type person because you'd have to like go 6 away, look at it, and then get back to the branch -- 7 there was no issue in providing that postmaster with, 8 you know, a copy of that, because that's what you'd 9 based your conclusion on, really. 10 Q. Do you know what triggered the change to HORice? 11 A. So my recollection was, so I got called to a meeting by 12 Fujitsu. I think it was Tony Jamasb from service 13 management. So there was myself, Anne Allaker and we 14 went to Bracknell, we got invited to a meeting with 15 Fujitsu where they actually showed us a demonstration of 16 HORice. Myself and Anne were involved in the Branch 17 Support Programme at the time and it was positioned to 18 us as would this -- what benefit would this bring the 19 Post Office if you had -- if you had access to this 20 system? It was -- I think it was based on what they 21 were using to track, like, whether terminals were down 22 and that kind of stuff. 23 So as part of that exercise I went back and sort of 24 talked to various people within the business, like 25 Angela van den Bogerd and, you know, we looked at, well, 95 1 what benefit would this give? And then we'd obviously 2 just implemented the project and then deployed it, 3 because it was felt that, actually, it could provide 4 some real help, and try and to resolve some issues and, 5 you know, reduce this reliance on the ARQ but also give 6 postmasters a quicker resolution time in terms of 7 somebody being able to see the data, rather than it just 8 being in a closed shop. 9 Q. When it was presented to you by Fujitsu, had they 10 expressed any concerns or frustrations relating to the 11 provision of ARQ data? 12 A. Not that I'm aware of. Not as part of that meeting. 13 Q. Were you aware of any concerns within the Post Office 14 about the difficulties in obtaining ARQ data? 15 A. I think the main concern that I was aware of was the 16 cost, if you wanted -- there were additional stuff over 17 the quota. I don't know whether it was necessarily 18 an issue of not getting hold of the data. I think 19 sometimes there was a question of who would pay for it, 20 if it was needed, because it didn't fit within the -- 21 what you were allowed. 22 MR BLAKE: Okay. Thank you very much. 23 Sir, that's an appropriate time -- 24 SIR WYN WILLIAMS: While it's on our mind, can I just ask 25 one or two more questions about the appeal process? 96 1 A. Yeah. 2 SIR WYN WILLIAMS: Apart from the time when Mr Bayfield took 3 over all the appeals, you said you were part of a group 4 doing them. 5 A. Yes. 6 SIR WYN WILLIAMS: Approximately how many of you? 7 A. Um, I think there was about 15, 20 people. 8 SIR WYN WILLIAMS: So, in any given year, let's put it in 9 that way to start with, how many do you think you 10 personally would do? 11 A. I think it was about three or four we'd get. 12 SIR WYN WILLIAMS: Three or four a year? 13 A. Yeah. 14 SIR WYN WILLIAMS: Fine. So as a guesstimate, in the period 15 between 2006, 2018, taking out Mr Bayfield's time, 16 overall, 20, 30 appeals, that sort of thing? 17 A. Yeah, that probably seems about right. 18 SIR WYN WILLIAMS: Right. Don't be too legalistic about it 19 but your decision, were you reviewing what the contracts 20 manager had done or were you actually looking at it all 21 afresh and coming to your own decision? 22 A. I think you were supposed to do the former, I tended to 23 do the latter. 24 SIR WYN WILLIAMS: Right, well that's not entirely 25 surprising. So there was a kind of process which told 97 1 you what you should do? 2 A. Yes. 3 SIR WYN WILLIAMS: So it was a review, I'll call it 4 a review. 5 A. Mm-hm. 6 SIR WYN WILLIAMS: But you being you decided to look into it 7 for yourself? 8 A. Yeah. 9 SIR WYN WILLIAMS: Is that it? Okay. How often did the 10 appeal succeed roughly? 11 A. Not very often. I never overturned one once. 12 SIR WYN WILLIAMS: Right. Well, that's fine. 13 There was one other short point that's just eluding 14 me for the moment. Yeah, were the appeals in the main 15 made when someone had had their contract terminated, or 16 were there appeals about other things as well? 17 A. Um, it was -- the contract ones was usually about -- 18 formal appeal would be when the contract was terminated. 19 SIR WYN WILLIAMS: Yes. 20 A. You would get sort of individuals where a decision had 21 been made that, like a transaction correction or 22 something, and there was -- you might get asked to 23 review a decision. 24 SIR WYN WILLIAMS: But of the approximately 30 appeals that 25 you dealt with, were they, the vast majority, where the 98 1 contract had been terminated? 2 A. Yes. 3 SIR WYN WILLIAMS: Right. Thank you very much. Okay 2.00. 4 (1.03 pm) 5 (The Short Adjournment) 6 (2.00 pm) 7 MR BLAKE: I'm going to move on to the topic of Second 8 Sight. Did you have any direct contact with Second 9 Sight? 10 A. No. 11 Q. Can we look at POL00106194, please. It's the final page 12 of that document that I'd like to start with. This is 13 an email chain that is ultimately forwarded to you, or 14 you're a copy recipient? 15 A. Yes. 16 Q. But I'm going to start at the back. The penultimate 17 page, page 4. Thank you very much. So there is 18 an email at the bottom there from Antonio Jamasb? 19 A. Jamasb. Yeah, Tony Jamasb. 20 Q. What was his role? 21 A. I think he worked in service management in the IT 22 department. 23 Q. Do you know Dave? 24 A. Dave Hulbert, yes. So Dave was in managed services so 25 I think he was something to do with the relationship 99 1 with Fujitsu and IT. 2 Q. Thank you. I'll just read that, it says: 3 "The NBSC has been provided with no information 4 regarding the Audit Press Release ..." 5 Do you recall what the audit press release was? 6 A. I can't remember the detail. Looking at this email that 7 you've presented earlier, I am assuming that some kind 8 of statement was released about the potential review 9 with Second Sight. 10 Q. So it says: 11 "... so I have drafted the following and if you are 12 happy with it I will send it onto NBSC. 13 "As discussed if we get any enquiries from Branches 14 regarding the recent press release from Post Office 15 regarding the independent audit of the Horizon System 16 please use the following quote ..." 17 So this was a proposal to send this to those who 18 worked on the NBSC. 19 A. Yes, because they would have been getting calls from 20 branches asking, you know, they would have seen it in 21 the local press or national press and it would have 22 generated some activity. 23 Q. We will see from the later emails but it seems as though 24 the concern is that the NBSC -- 25 A. They don't know what to do with it, yes. 100 1 Q. And they have received requests from audits of branches? 2 A. Yes. 3 Q. The line to take there is: 4 "The Post Office continues to have absolute 5 confidence in the robustness and integrity of its branch 6 accounting processes. 7 "Over the past 10 years, many millions of branch 8 reconciliations have been carried out with transactions 9 and balances accurately recorded by more than 25,000 10 different subpostmasters." 11 Was that a line you were familiar with at all? 12 A. I think that was what ended up being used quite a lot 13 within the communications. 14 Q. Do you know where it was coming from? 15 A. I'm not sure where it came from, to be honest, Julian. 16 Q. If we go up in this chain and the email on the second 17 page -- or third page, sorry. Friday, 22 June, 2.38 -- 18 thank you very much. It says there "As discussed", it's 19 the italicised part: 20 "As discussed if we get any enquiries from Branches 21 regarding the recent press release from Post Office 22 regarding the independent audit of the Horizon System 23 please use the following quote ..." 24 That's the quote. Below the quote, it says: 25 "However, some branches may request to be involved 101 1 in this exercise. Advise them that we will forward 2 their details on to the relevant department, but at this 3 time you have no further details." 4 A. Yeah. 5 Q. If we could scroll up again in the chain, to the top of 6 the second page, this in email from Kevin Gilliland, is 7 it? 8 A. Gilliland, yes. 9 Q. It says there -- sorry, if we can scroll to the second 10 page. Yes, there we go: 11 "Please can we be absolutely clear that we should 12 make no reference to the option of the audit unless it 13 is specifically requested. I am sure that all calls 14 will be seeking clarification about the statement and we 15 don't want to cause unnecessary work and process." 16 What do you understand Kevin to have meant in that 17 email? 18 A. I think he's making the assumption that people are just 19 asking the question about the press release and I would 20 interpret it that he doesn't want to offer the audit 21 unless they ask for it. That's what I read from that. 22 Q. So there's a press release that it seems to be about 23 Second Sight's involvement? 24 A. The request to be involved I think, yeah. 25 Q. Yes. Who was Kevin? Can you remind me, sorry? 102 1 A. Kevin was the network director. 2 Q. So the network director at that stage was saying that we 3 don't want to give people the option of the audit? 4 A. Unless they ask for it. 5 Q. Yes. If we scroll up to the first page, we have those 6 emails forwarded to yourself. Do you know why you were 7 included in this chain? 8 A. Yeah, so I worked for Craig at the time, so people on 9 copy -- so you've got Tony Jamasb and myself, John 10 Breeden, Lin and I think probably Sue did, so we were 11 part of Craig's lead team. 12 Q. I will just read the second at third paragraphs. It 13 says: 14 "Taking Kevin's point, I would hope that we do not 15 get a great number as it should not be 'offered' but 16 than you pick up and maintain the request list within 17 your team please?" 18 Are you aware of there being a list of branches that 19 have called in following this press release? 20 A. Yeah, because we had to set up a process on the back of 21 that. So I worked with Pat to understand which branches 22 were actually ringing in and it was then obviously 23 working with Angela to decide what would happen with 24 those branches who'd made that request. 25 Q. Are you able to tell us, were those branches offered 103 1 an audit by Second Sight or offered something that they 2 hadn't been offered before? 3 A. I think Second Sight were made aware of the request to 4 be included. I don't know what the decision process was 5 about which ones would be included or not. We would 6 have just forwarded the list. 7 Q. Are you aware of somebody having that contact with 8 Second Sight to forward the list? 9 A. I think that was done through Angela van den Bogerd. 10 I didn't have any contact with them directly. 11 Q. It says: 12 "I'd like to understand the nature/reason background 13 as would normally when anything is escalated from NBSC. 14 As we always say a physical audit at branch counts how 15 many beans are there at that time, it doesn't do 16 anything else and certainly doesn't test the system 17 which is what I believed the independent review is 18 about. Let's see how it develops." 19 Was there an understanding within the Post Office 20 that a physical audit at branch couldn't really test the 21 system that was being used. 22 A. Yeah, I don't think it was there to decide whether the 23 system, like, was functioning correctly from an IT 24 perspective. It was a verification of stock and assets, 25 stock and cash. You had the financial audit and then 104 1 the compliance audit. I don't think there was any 2 provision for an IT audit as such. 3 Q. Did you have any further involvement in this particular 4 issue? We'll get on to some meetings that you had with 5 lawyers, et cetera, but in terms of this specific issue 6 about people calling the NBSC, aware of the Second Sight 7 issue? 8 A. Yeah, so I think this was the start of the 9 communications, so this was the list that obviously was 10 then forwarded to Second Sight to include. There was 11 then processes that we put in place on the back of that 12 to record, and make sure we resolved any branches that 13 were raising concerns about Horizon Issues, which then 14 formed part of the weekly call with the various 15 stakeholders, which is part of the agenda that you've 16 included in the pack. So this was almost like 17 a precursor to those. 18 Q. So we see and we'll come to those Bond Dickinson notes? 19 A. Yes. 20 Q. Is that related to this? 21 A. It will be. That will be the end part. This was 22 obviously just the start of obviously the processes that 23 were followed. They ultimately ended up in those Bond 24 Dickinson conversations. 25 Q. Thank you. Can we look at POL00029744. This is the 105 1 interim report produced by Second Sight. The date of it 2 is July 2013, so we're now a year on. 3 A. Yes. 4 Q. Can we turn to page 5, please. Did you see this report 5 at the time that it was produced? 6 A. I can't recollect. The first time that I think I saw it 7 was when you sent me it. 8 Q. Let's go through a few of their observations and 9 conclusions. Can we look at paragraph 6.4, the bottom 10 of page 5. It says: 11 "In the course of our extensive discussions with POL 12 over the last 12 months, POL has disclosed to Second 13 Sight that, in 2011 and 2012, it had discovered 14 'defects' in Horizon Online that had impacted 76 15 branches." 16 At this time, was that something you were aware of 17 at all? 18 A. No. 19 Q. If we go over the page, please, the first defect is 20 referred to as the receipts and payments mismatch 21 problem, paragraph 6.6. The second defect referred to 22 as the local suspense account problem. Paragraph 6.7. 23 "POL was unaware of this second defect until, a year 24 after its first occurrence in 2011, it reoccurred and 25 an unexplained shortfall was reported by 106 1 [a subpostmaster]." 2 Paragraph 7.1: 3 "It has become clear that whereas the Horizon System 4 appears to achieve its intended purpose almost all of 5 the time and operates smoothly for most [subpostmasters] 6 and their staff, some combinations of events can trigger 7 situation where problems occur." 8 Had those kinds of issues been brought to your 9 attention at all? 10 A. No. 11 Q. If we go over the page to page 8, we have the 12 preliminary conclusions because this is, of course, the 13 interim report of Second Sight? 14 A. Yes. 15 Q. 8.1: 16 "This is an Interim Report and there is much work 17 still to be done. Any conclusions reached at this point 18 will need to be updated in the light of new information 19 that arises as the Investigation continues." 20 Then it lists below that the preliminary 21 conclusions. The first is that: 22 "We have so far found no evidence of system wide 23 (systemic) problems with the Horizon System; 24 "We are aware of 2 incidents where defects or 'bugs' 25 in the Horizon software gave rise to ..." 107 1 That's the errors and bugs that we spoke of before 2 that hadn't been brought to your attention. 3 A. Yeah. 4 Q. "Occasionally an unusual combination of events, such as 5 power or communications failure during the processing of 6 a transaction, can give rise to a situation where 7 timely, accurate and complete information about the 8 status of a transaction is not immediately available to 9 a [subpostmaster]." 10 Is that something that had been brought to your 11 attention? 12 A. Not before then, but I think on the back of this they 13 did some work with the -- it was called the fallback and 14 recovery process. So I think following this interim 15 report I think there was a recommunication back out to 16 branches because it was quite a complicated process to 17 follow to. If your connection was lost, there were 18 certain transactions that you could recover immediately 19 and ones that you couldn't. So I think I became aware 20 of that through the subsequent comms that they did on 21 the back of this. 22 Q. So your understanding of that at the time was that it 23 was a power cut or something like that would cause 24 a recovery issue? 25 A. It's the power cut or the communication side. So, you 108 1 know, if the Internet signal cut out mid-transaction, 2 there'd be procedures that the branch would have to 3 follow to recover that transaction. 4 Q. Then (d): 5 "When individual [subpostmasters] experience or 6 report problems, POL's response can appear to be 7 unhelpful, unsympathetic or simply fail to solve the 8 underlying problem." 9 That's something that we will come on to look at 10 because that's something that I think you looked at in 11 depth. 12 A. Yeah. 13 Q. (e): 14 "The lack of an effective 'outreach' investigations 15 function within POL, results in POL failing to identify 16 the root cause of problems and missing opportunities for 17 process improvements." 18 Then (f): 19 "The end of Trading Period processes can be 20 problematic for individual [subpostmasters], 21 particularly if they are dealing with unresolved 22 Transaction Corrections ... The lack of a 'suspense 23 account' option means that it is difficult for disputed 24 TCs to be dealt with in a neutral manner." 25 Now, you say you first saw this report -- 109 1 A. When you sent me it. 2 Q. In the pack for the Inquiry? 3 A. Yeah. 4 Q. Let's look at the Branch Support Programme. What was 5 the purpose of the Branch Support Programme? 6 A. So that was set up on the back of I'd received the 7 information second time around, some of the thematic 8 issues that might come through. So, as a result of 9 those conversations the Branch Support Programme was set 10 up, and that's what I was asked to lead. 11 Q. Can we look at POL00039158. Thank you. Is this 12 a document that you are familiar with? 13 A. Yes, I think I wrote it because my name is on the top. 14 Q. Thank you. If we look at the background, I'll just read 15 that first paragraph, it says: 16 "To address the concerns about the Horizon System 17 that have been raised by some subpostmasters over recent 18 years, the Post Office commissioned an independent 19 review of their cases." 20 So that's the Second Sight review. 21 A. Yeah. 22 Q. "The company that conducted the review issued an interim 23 report on ... 8 July 2013. The review made it clear 24 that the Horizon computer system and its supporting 25 provides function effectively across our network." 110 1 Now, having not read the Second Sight report 2 yourself, where was that message coming from? 3 A. So that would have been conversations with myself and 4 Angela van den Bogerd. 5 Q. So is it something that Angela van den Bogerd had told 6 you? 7 A. Yes, as part of our discussions, part of the initiation 8 of the programme. 9 Q. Do you think it was unusual to be taking forward 10 a programme that was based on a report that you hadn't 11 read? 12 A. In hindsight, yeah, I should have asked to see the 13 report but I trusted the information that was being told 14 to me. 15 Q. Thank you. If we look at the "Scope", slightly down on 16 the page, it says: 17 "The interim report identified the following areas 18 of concern which will be included within the scope of 19 the Programme. 20 "Post Office's attitude to subpostmasters which is 21 often defensive and unsympathetic ..." 22 So that's very close to what was written in the 23 report itself. 24 A. Yeah. 25 Q. "Inadequate Helpdesk support with responses that are 111 1 script based, coupled with a decrease in overall branch 2 support. 3 "Lack of timely, accurate and complete information 4 provided to subpostmasters to support them in resolving 5 issues. 6 "Inexperienced trainers and gaps in training 7 coverage. 8 "Lack of centralised data or files specific to each 9 branch which hinders the quality investigation from 10 taking place." 11 Now, some of those do match what the Second Sight 12 report was saying. 13 A. Mm-hm. 14 Q. There is, of course, the absence there of the mention of 15 the bugs and defects? 16 A. Yes. 17 Q. Was that something that anybody mentioned in the context 18 of your programme? 19 A. No. 20 Q. One other thing, I think, that was missing from this 21 scope was the reference to (f), which was the lack of 22 a suspense account function, in the Second Sight report; 23 do you recall that final reference? 24 A. Yeah, I wasn't asked to look at that. 25 Q. Were you aware of that being a concern? 112 1 A. I think at like a higher level, yeah. 2 Q. Insofar as those were findings or based on findings from 3 Second Sight, do you agree that those were problems 4 within the Post Office? 5 A. Yes. 6 Q. Can we turn to page 2, please. Looking there at the 7 "Governance and key stakeholders", it says: 8 "Alice Perkins and Paula Vennells have requested the 9 establishment of the Programme which will be led by 10 Angela van den Bogerd. Gayle Peacock will be 11 accountable for running the Programme on an operational 12 level." 13 Had Ms van den Bogerd spoken to you about the Second 14 Sight report? 15 A. Yes, she will have done, yes. 16 Q. Was she the direct channel from which you were getting 17 the summary of that report? 18 A. Yes. 19 Q. Did you speak to Alice Perkins or Paula Vennells at all? 20 A. Never Alice. I think I spoke to Paula once during the 21 programme but my interactions were with Angela. 22 Q. Did any of them express any particular opinion on the 23 Second Sight investigation, the quality of that 24 investigation, whether they disagreed or agreed with it? 25 A. I was given an indication that they probably weren't in 113 1 the same place as Second Sight and the conversations 2 were difficult but that was as far information that was 3 shared with me. 4 Q. Who was sharing that information? 5 A. That was with Angela. 6 Q. If we look down on this table, these are the different 7 key stakeholders. We have there, for example at the 8 bottom, Rod Ismay, Andy Winn from Finance. 9 A. Yes. 10 Q. Were they people who you discussed problems with 11 Horizon? 12 A. Yes, so I'd had, like, working relationships with Rod, 13 and Andy from my days as network co-ordination. 14 Q. Did they express any concerns about the operation of 15 Horizon? 16 A. I don't think so. 17 Q. If we go over the page to "Key Deliverables", so: 18 "The Programme will be responsible for delivering 19 the following: 20 "Mapping the 'as is' process for providing branch 21 support and the various touch points for branches. 22 "Undertaking a gap analysis for each of the 23 respective areas regarding the concerns raised in the 24 interim report. 25 "Producing recommendations for how the relevant gaps 114 1 will be closed, supported by a deployment and resource 2 plan." 3 Was the plan, as far as this programme is concerned, 4 to look at things as they then stood rather than look 5 back at historic cases or did you intend to look at 6 historic cases as well? 7 A. I think it was as they stood then. 8 Q. So the reference to "as is" for example, is that -- 9 A. Yeah, it's the current business operating model. 10 Q. Are you aware at this time of any consideration being 11 given to how problems that had been identified by Second 12 Sight in their independent report had impacted 13 potentially on historic prosecutions, terminations, 14 suspensions and things like that? 15 A. I knew that obviously there was discussions around if 16 the prosecution policy was actually going to continue or 17 not. I didn't know anything about the individual cases. 18 Q. I mean, let's say those appeals that you had been part 19 of, the termination appeals, did at this stage, knowing 20 at least the information that had been provided to you 21 about the Second Sight report, did that raise any 22 concerns with you about whether people had been unfairly 23 terminated previously? 24 A. Not at that stage because the message was that Horizon 25 was generally okay. 115 1 Q. The message from who? 2 A. I think it was just generally across the business. That 3 was just the message that was given. 4 Q. Where, at that time, did you consider that message was 5 coming from? 6 A. I think it was top down, to be honest. 7 Q. "Top" being? 8 A. Board level. 9 Q. Can we look at page 4, please. "Key Performance 10 Indicators and Measures", you have there, if we scroll 11 down, a mention of branch losses and debt and then 12 mention of system, robustness of the system. Do you 13 recall how these KPIs were being measured at all? 14 A. I can't recall those. 15 Q. Then the final, page 5, at the bottom of page 5, 16 7 August 2013 is version 3 of this document. It says: 17 "Input from Programme Board to include additional 18 names, Programme approach, definition of what good looks 19 like and confirmation that the Programme will be run by 20 Gayle Peacock." 21 Who in particular do you recall inputting into these 22 terms of reference. It says the programme board but was 23 there anyone who was particularly active or particularly 24 involved? 25 A. No, I think it would have been shared with all the 116 1 stakeholders as well, you know, if you're named in the 2 document you should see it, so I think they would have 3 all seen it plus Paula and Angela. 4 Q. Did you ultimately produce a report arising from these 5 terms of reference? 6 A. I can't recall specifically an end report. I know there 7 was reports in terms of some of the measures on 8 a regular basis, so some of the things that you 9 mentioned in the table above in terms of how things were 10 tracking. I remember producing those on a monthly 11 basis. I don't know what the end, if there was an end 12 report. I finished on maternity leave before the 13 programme actually finished. 14 Q. Are you aware of recommendations having been made? 15 A. Yeah, so there was a number of recommendations. So 16 there was the Branch User Forum, which was implemented, 17 there was the investigations team which was the -- 18 I can't remember the term that was used but this was 19 like the investigative function to look at the losses. 20 There was the recommendation to implement the case 21 management system. HORice came out of the back of this 22 as well, which we talked about earlier. There was some 23 tactical changes that were made in terms of things like 24 remittance slips were changed because one side didn't 25 look like -- there was a pick list versus what the 117 1 branch would rem in, which was confusing. 2 So there were tactical things, there were duplicate 3 receipt changes, so there were a number of things that 4 were done rather than just wait for the end report but 5 I can't remember the end report as such because I didn't 6 produce it. 7 Q. Do you know who produced it? 8 A. I don't know if there was one. 9 Q. Can we look at POL00043369. I am going to start to go 10 through these Bond Dickinson reports. 11 A. Okay. 12 Q. Can you tell us the context of those reports? 13 A. So these were the notes that were taken from a weekly 14 meeting, so there was a number of business stakeholders 15 that took part in the calls. They were chaired by Bond 16 Dickinson and Legal Services, and the purpose was to 17 understand if there was any branches or issues or 18 technical issues that the business actually needed to be 19 aware of. So it was actually, you know, were there any 20 calls coming to NBSC that we were aware of? Was there 21 anything that was being raised to myself or through 22 other channels that the business needed to be aware of 23 and make sure that the branches issue was actually being 24 resolved by the appropriate person. 25 Q. Was it triggered by the Second Sight report? Was it 118 1 triggered by threatened litigation or something else? 2 A. I can't remember why they were initiated. They were 3 just asked to participate obviously with looking at 4 improvements that could be made for that purpose. 5 Q. Were you aware, for example, of the Justice for 6 Subpostmasters Alliance around this stage, 2013? 7 A. Yeah, in terms of how it was, you know, on the back of 8 the Second Sight work that was being done. 9 Q. So this is the 2 October. You're mentioned there under 10 "Network". 11 A. Yeah. 12 Q. If we turn to page 3, please. They all follow a similar 13 layout, so let's say we have "Nelson" there. What does 14 that mean? 15 A. That would have been a particular branch that was Nelson 16 Post Office. 17 Q. It says there: 18 "GP [I think that's yourself] has provided the discs 19 to Helen Rose." 20 Do you recall this at all? 21 A. I recall conversations about Nelson Post Office branch. 22 I'm assuming that those were motor vehicle licence discs 23 that had been returned, I think, the only thing that 24 would be discs. 25 Q. Do you know who Helen Rose was? 119 1 A. Helen Rose worked in the fraud investigations team. 2 Q. Do you remember her writing a report about Horizon? 3 A. I have seen it's referred to in the additional 4 documents. I haven't seen that report. 5 Q. You didn't see it at the time? 6 A. No. 7 Q. Then it says: 8 "GP made the point that the Horizon issues had 9 already been dealt with and those should not have been 10 raised at the visit." 11 Do you remember that? Are you able to assist us at 12 all? 13 A. Yeah, I think -- so this was a case that the business 14 were already communicating with, so I think this was one 15 that like the case review team were looking at in terms 16 of different things that could be causing the 17 discrepancies. I can't recall what visit that alludes 18 to, I'm assuming that somebody went out to the branch. 19 Yeah, that's really the only thing I can remember for 20 that. 21 Q. We'll continue going through those documents but before 22 I do I just want to bring to your attention POL00029677 23 and that is what we know as the Detica report of 24 1 October 2013? 25 A. Yeah. 120 1 Q. So we're in October. This was a document that was in 2 your pack. Have you ever seen this before? 3 A. I can remember reading it because I think, as part of 4 the input it mentions the non-conformance team, which 5 would have been the branch standards team. So I can 6 remember, I think, the Detica team did come and speak to 7 I think it was some of my team in terms of the data 8 sources that we used, particularly for branch standards. 9 So I think I did see this at the time. 10 Q. Can we look at page 11. We have there in the top 11 paragraph it summarises the Second Sight report and what 12 they thought of the Second Sight interim report. It 13 says: 14 "The initial findings of Second Sight were published 15 during the Pilot. The review was prompted by a public 16 campaign by [subpostmasters] who felt they had been 17 traduced by the Post Office following losses at their 18 branches. Several of Second Sight's observations 19 resonate strongly, notably the disjointed response by 20 the Post Office and the habitual desire to assign 21 responsibility to an individual rather than to conduct 22 root cause analysis to close gaps persisting across the 23 branch network. In order to have a consistent approach 24 across the [subpostmaster] estate, it is vital that Post 25 Office has the ability to robustly identify and monitor 121 1 anomalous behaviour, so the appropriate corrective 2 action can be taken (whether this is tactical education, 3 enhanced training, process or system redesign or 4 audit/investigation)." 5 That's something you would have read at the time. 6 A. Mm-hm. 7 Q. Again, I mean did that cause you any concern about, for 8 example, having conducted those appeals in relation to 9 terminations? Did you begin to have any concerns about 10 the Horizon System? 11 A. Not on the Horizon System itself, no. 12 Q. If we can look at page 37 and 7.2.2, "Complex and 13 fragmented systems": 14 "Post Office systems are not fit for purpose in 15 a modern retail and financial environment. Our primary 16 concern here relates to difficulty in reconciling 17 information from multiple transaction systems both in 18 terms of timeliness, structure and access." 19 Are you aware of this report having caused anyone, 20 for example those who attended those meetings 21 Deloitte -- with Bond Dickinson, sorry, any concerns 22 about the Horizon System. 23 A. I don't think so. I don't think this report sort of 24 highlighted any problems with Horizon. 25 Q. So you didn't read that as being related to Horizon? 122 1 A. Not how Horizon was performing itself. I think there 2 was the acknowledgement that the system integration and 3 the multiple systems wasn't easy but I don't think we 4 read that as that undermined Horizon itself. 5 Q. The references to the Second Sight report that I took 6 you to earlier and about concerns about not conducting 7 root cause analysis to close gaps persisting across the 8 branch network, and things like that, that didn't cause 9 any concerns relating to the Horizon System? 10 A. No, I don't think so. 11 Q. Can we look at POL00043370. It's another one of those 12 meetings, 9 October. In that first box we have mention 13 of: 14 "Helen to see if she can link transactions to 15 specific time. GP to report update in due course." 16 Was that Helen Rose again? 17 A. Yes, it was, yeah. 18 Q. Do you recall what this might be talking about at all? 19 A. I think Helen must have been looking to see if there was 20 any investigation that she was doing. I'd have asked 21 her to undertake an investigation for the press brief, 22 to see if there was any information that she could 23 provide. 24 Q. If we go over to page 2 and it's the bottom of page 2 25 that I'd like to look at. Andy Hayward from Security. 123 1 Is this the person who was reporting a particular issue? 2 A. Yes, it would have been, yes, so the person on the left 3 is the person who is speaking. 4 Q. So: 5 "2004 -- Carluke Post Office -- Police prosecution 6 believed to have happened. Blaming Horizon at the time. 7 Elaine Doram SPM passed away. Husband blaming Horizon 8 and making noise through Scottish Parliament. Email 9 details to forwarded. No information due to time lapse. 10 No records available. No further enquiries at this 11 stage." 12 Was there, at this stage -- so we're still October 13 2013 -- any questioning amongst those who attended these 14 meetings or amongst the senior leadership of the safety 15 of those kinds of prosecutions? 16 A. That wasn't discussed on this call, no. 17 Q. It's referring to a 2004 case, so was it looking back or 18 was it because somebody had called -- 19 A. The purpose of the call was obviously to -- you know, 20 any conversations that were being had, so Andy would 21 have raised that as part of this weekly meeting to say 22 this issue has now been raised and, actually, as the 23 business, you need to be aware that the case from 2004 24 has now been raised and people are starting to talk 25 about it again. 124 1 Q. Was nobody querying at that meeting or at the series of 2 meetings, any concern about the reliability of 3 convictions? 4 A. We didn't discuss it. 5 Q. At this meeting and at many of the meetings you have 6 people from the legal team, so Rodric Williams, Jarnail 7 Singh, Martin Smith of Cartwright King, Kayleigh 8 Harding. You'll have seen in your pack that there was 9 advice given by a barrister, Simon Clarke, on 15 July 10 2013 -- 11 A. Yes. 12 Q. -- so before these meetings took place. I don't need it 13 to be brought on screen but, for the purpose of the 14 transcript, it's POL00006357. That raised serious 15 questions about expert advice that can be given in 16 prosecutions. 17 A. Yes. 18 Q. Were you aware of that at this time? 19 A. I'd never seen that report until you sent it. I was 20 aware that they were stopping the prosecutions but 21 I didn't know the reason why. 22 Q. Martin Smith of Cartwright King, for example, or Jarnail 23 Singh, did any of them ever mention Gareth Jenkins, for 24 example, at any of those meetings? 25 A. It was mentioned that he was the expert witness that was 125 1 often used in prosecutions but, other than that, Gareth 2 wasn't discussed. 3 Q. So there was no mention of any concern about the 4 reliability of his evidence? 5 A. No. 6 Q. What was the general attitude of those present when 7 things like Carluke Post Office were bought up? Was 8 there some scepticism? 9 A. Um, I don't think so. I can't -- 10 Q. The reason I ask is the way it's phrased here, "Husband 11 blaming Horizon and making noise through Scottish 12 Parliament". Making noise is a phrase that cropped up a 13 couple of times. 14 A. It's derogatory, yeah, because they don't believe it, 15 I guess -- I don't know why they would have used that 16 phrase. The notes were written as somebody said it but 17 I can understand how that's interpreted that, yeah, 18 there's a cynical view that it's been made noise. 19 Q. How did that kind of language sit with, for example, the 20 Branch Support Programme that had been going on, a more 21 listening approach, perhaps, to branches, the branches' 22 concerns? 23 A. I didn't pick up on that at the time and I perhaps 24 should have. 25 Q. Can we look at POL00043371. 16 October now. So there 126 1 are lots and lots of meetings. This is a very intense 2 period of -- 3 A. It was weekly, yeah. I can't remember for how long but 4 it was every Wednesday for a number of months. 5 Q. Do you know who instigated them? 6 A. I think it was Security, I think. 7 Q. So they had asked for this series of meetings to take 8 place? 9 A. Yeah, and I presume it was on the back of obviously 10 having seen the information about the disclosure 11 document in the pack, that this was deemed to be the 12 right forum to make people aware of what was going on in 13 the business. 14 Q. When you say disclosure, do you mean the Simon Clarke 15 advice? 16 A. Yes. 17 Q. So you hadn't seen the advice? 18 A. No. 19 Q. Were you aware of it? 20 A. No. 21 Q. Were you aware of some other purpose for the meetings? 22 You've drawn the link between the Simon Clarke advice 23 and the meetings, can you now reflect on it and think 24 that there was a link? 25 A. Having now seen the document, I now view it differently 127 1 to how I did before. Before my view was actually we 2 just needed to get these branch issues resolved, (a) 3 know about them and (b) do something about it. Now, 4 having seen the documents that led to it, it puts 5 a slightly different view on it. 6 Q. We have there attending this meeting security Dave 7 Posnett. 8 A. Mm-hm. 9 Q. Is he someone you knew well? 10 A. Yeah, I knew him reasonably well. He worked, I think, 11 in the fraud team in Security. 12 Q. If we turn to page 2, about halfway down in the 13 left-hand column you have the name "Martin Griffiths"? 14 A. Yes. 15 Q. It says there "DP", that's presumably Mr Posnett? 16 A. Yes. 17 Q. "... No further details on Horizon issue. SPM passed 18 away." 19 Were you aware that Mr Griffiths was terminated in 20 the summer of 2013 and on 23 September 2013, he 21 committed suicide and on 11 October, so just shortly 22 before this meeting, his life support machine had been 23 turned off. 24 A. I think this was -- I was aware of -- that he'd 25 attempted to commit suicide. I think this was the 128 1 meeting where it was confirmed that he had passed. 2 Q. So there was discussion at these meetings of 3 Mr Griffiths having -- 4 A. Passed away. 5 Q. It says "passed away" there but the actual background, 6 was that discussed. So that the link, for example, to 7 Horizon, was any link drawn between his suicide and 8 Horizon? 9 A. We knew that, I think, obviously there was claims being 10 made at the time. 11 Q. What was the attitude at this meeting: condolences, 12 concern or business as usual? 13 A. Well, it's obviously condolences as well. It's never 14 nice when somebody passes away. 15 Q. But was that the atmosphere at the meeting? Was 16 there -- it may strike people as a significant moment in 17 time, in the history of Horizon. Did it strike anybody 18 on that occasion as significant or not? 19 A. I think it would have done, I can't particularly 20 remember the instances of this particular call. 21 Q. If we go down, please, to South Darenth: 22 "Question as to whether NBSC properly capturing 23 complaint." 24 Not in relation to this particular incident but just 25 speaking more broadly, were there concerns that the NBSC 129 1 weren't properly capturing complaints? 2 A. I think so and that was one of the things that we were 3 looking at as the Branch Support Programme, is how can 4 you get advisers to -- because I think it was quite 5 apparent that people were just putting "KB", so you'd 6 look at like a call log history into the Network 7 Business Support Centre to try to find at what had 8 happened and there were instances where the adviser was 9 putting "KB" which referred to Knowledge Base. So they 10 weren't actually recording in some instances what had 11 been said to the postmaster and this was the work that 12 we were trying to do with them, because actually when 13 you're trying to look at a case, KB isn't a useful piece 14 of information to work out what happened or what was 15 told to the subpostmaster to try and rectify any 16 problem. 17 Q. Do you know how long that had been going on for? Is 18 that a historic problem, a long lasting problem? 19 A. I think it was fairly historic, yes. 20 Q. If we scroll down over the page it says: 21 "RW -- Once Horizon disputed, it needs to be 22 flagged. SPM to be questioned as to where discrepancy 23 exists. To prevent further issues in debt recovery 24 process." 25 What do you understand that to mean? 130 1 A. I think Rodric was just reinforcing the fact that, as 2 soon as anybody mentions any concerns, actually we need 3 to know about it. 4 Q. If we scroll down on this page, please, there is 5 an entry there with "GP" on the left-hand side at the 6 bottom. It says: 7 "Rodmill -- issues log amalgamated. Complaint sent 8 before Second Sight came into play. Direct to Paula." 9 Are you able to tell us what you think that meant? 10 A. I think that would have been a complaint that would have 11 gone into Paula before the Second Sight work had 12 actually been commissioned. 13 Q. So are you aware -- and we will come on to this because 14 I know you were part of the executive correspondence 15 team -- but did subpostmasters and others send 16 complaints direct to Paula Vennells? 17 A. Yes. 18 Q. Where would they go from there, typically? 19 A. It would depend on what the complaint was about. So it 20 was usually, depending on the nature of the complaint 21 that it was raised, it would be taken up with the senior 22 manager responsible for that department. So if it was 23 a Post Office kept closing, it would be the regional 24 manager. If it was a stock or cash issue, it would be 25 supply chain. If it was branch accounting, it would go 131 1 to the head of branch accounting, and they would be 2 responsible for investigating the complaint and then 3 providing a resolution. 4 Q. It says: 5 "Complaint cited many issues with Horizon. Stock 6 reconciliation, numbers do not match and challenged. 7 Recording of 1st and 2nd class label sales. Not clear 8 whether this has been investigated." 9 Is this something you remember, this particular 10 incident? 11 A. I can't remember this but I think it would have been 12 triggered by the executive correspondence team. 13 I didn't manage them at the time but they would have 14 approached us, based on the work we were doing and 15 saying, "You need to have a look at this one because we 16 think that's got further evidence." 17 Q. If we scroll over the page, it says: 18 "GP to look into which branches with complaints that 19 have not been dealt with and report back." 20 A. Yeah, so that would have been going through the logs 21 with the executive correspondence team, so they captured 22 all of the complaints that were fed to Paula. So I'm 23 assuming with that it would have been looking back on in 24 any historic records and seeing if there were any 25 similar ones that had been overlooked. 132 1 Q. Thank you. 2 I'm going to move on to POL00040066. If we could 3 zoom in on the top there, it says: 4 "Post Office Limited, Initial Complaint Review and 5 Mediation Scheme, Overview of Horizon and Branch trading 6 practices." 7 Can you tell us the background to this document? 8 A. I can't remember the document but obviously I must have 9 input it at some point because my name is on there. 10 I think it was produced on -- in preparation for the 11 mediation process or there were a number of branches 12 that were going through that process to try to reach 13 an agreement on, you know, how to resolve their case. 14 I think this was various information that was put 15 together to try to give the mediator some knowledge 16 about Post Office branches and the types of issues that 17 they may have. 18 Q. Do you remember the period. I don't think it's dated, 19 this is a draft? 20 A. I think this would have been about 2014, I think. 21 Q. Thank you. If we look at page 23, we have there 22 a section entitled "Possible reasons for balance 23 discrepancies". I'll wait for it to be bought up on the 24 screen. As you said, it has your name here. 25 A. Yeah. 133 1 Q. It seems as though you co-wrote this with Angela van den 2 Bogerd or certainly -- 3 A. Collated some information or something, yeah. 4 Q. Do you know who would have written it or who would have 5 taken the lead with it? Would it have been you or 6 Ms van den Bogerd? 7 A. It was possibly me, I think. As I say, I can't recall 8 writing it but because my name is on there, I must have 9 input it at some point. 10 Q. You previously explained that Ms van den Bogerd was -- 11 had detailed knowledge of the Second Sight report -- 12 A. Yes. 13 Q. -- but at this stage you didn't? 14 A. Yeah, I hadn't seen it. 15 Q. If we look down, these are reported as possible reasons 16 for balance discrepancies. If we scroll down, the first 17 is a "Mis-key" so that's a staff entering the wrong 18 value. Over the page, "Connectivity", next, "Cheque 19 handling". Next, "Staff actions". There wasn't, in any 20 of this explanation of possible reasons for 21 discrepancies, any mention of bugs, errors or defects 22 with Horizon? 23 A. No. 24 Q. Having seen the interim Second Sight report now, are you 25 surprised that that wasn't mentioned? 134 1 A. Well, yeah, we would have included something -- if we'd 2 known there was the possibility of error, it should have 3 been included in there. 4 Q. During your discussions with Ms van den Bogerd in 5 relation to this chapter, or whatever we might call it 6 in this document, did she ever mention to you the 7 possibility of bugs, errors and defects as being 8 a possible reason for a balance discrepancy? 9 A. No. 10 Q. I'd like to look at your statement, please. I don't 11 have many questions left, just so we're clear for 12 timing. Your statement is WITN06160100and it's 13 paragraph 124, I'm going to give you the page number. 14 Page 42. So 124 you're talking I think about the HORice 15 system? 16 A. Yeah. 17 Q. Then 125, you say: 18 "The processes followed and improvements that 19 I identified were based on the assumption that the 20 Horizon System could not cause discrepancies and cash 21 shortfalls. Had I known then about the issues with the 22 system and the impact it could have had, then this would 23 have completely changed my approach to the processes 24 I was involved with." 25 You're talking here, I think, about 2014 and the 135 1 work you carried out in 2014. 2 A. Yeah. 3 Q. So as at 2014, despite working closely with Angela van 4 den Bogerd, you still, at that stage, weren't aware of 5 the fact that the Horizon System could cause 6 discrepancies -- 7 A. No. 8 Q. -- in cash shortfalls. I mean, looking back at that now 9 and considering that in what you now know, are you 10 surprised that you didn't know and can you come up with 11 an explanation as to why you think you didn't know and 12 weren't told? 13 A. I don't know, really. Whether it's because the Post 14 Office didn't believe that it could be an issue, so 15 discounted it. I don't know. 16 Q. If we scroll down to paragraph 129, that's page 43, you 17 say: 18 "Even when the claims about Horizon started to be 19 known within the business, the messaging coming from the 20 business was that the system was not capable of 21 impacting the accounts. I made the assumption that the 22 business had undertaken the relevant due diligence", 23 et cetera. 24 A. Yeah. 25 Q. You refer to the business. Are you able to tell us who 136 1 in the business you considered that messaging to be 2 coming from? 3 A. Well, it was evident in, you know, sort of the way that 4 the group exec was talking. You know, you've seen some 5 from the comms from Tony Jamasb, those kinds of 6 statements that was what was just in the business, that 7 was the language that was being used. 8 Q. Where in particular do you think that message was coming 9 from? Who in particular was that message coming from? 10 A. I would assume that that would be board. 11 Q. Anybody particularly? I mean, the board is made of 12 a number of people. 13 A. But I don't think anybody can just do that one message. 14 It's got to be -- the board have got to agree to those 15 messages. You know, when you're communicating something 16 so serious, I don't think it can just be one person that 17 says, "This is what it is". Everybody who is -- is 18 communicating that message at the board level needs to 19 sign up to that. 20 Q. Anybody in particular within the board that you felt was 21 driving that message? 22 A. Well, I think -- well, I don't know. I've no evidence 23 to suggest who it would be, you know. 24 Q. I'm going to move on to the Branch User Forum. I think 25 you've said it was established in 2014 and arose as part 137 1 of that work that you had been carrying out. 2 A. Yes. 3 Q. Who formed part of that forum? 4 A. So it was group of subpostmasters. So I think there was 5 a communication that went out to branches that invited 6 people to participate, and then they would literally 7 just apply, and a decision was made. Angela chaired it 8 I think the first time it was set up. I think there was 9 about six to seven postmasters, and then in 2017, when 10 Angela moved on to a different role, I took it over. 11 And we invited people to apply again, and took a range 12 of postmasters. 13 Q. Do you remember a subpostmaster called Tim McCormack? 14 A. I do. 15 Q. Do you recall any particular interaction with him? 16 A. Yes. 17 Q. Can you tell us about it? 18 A. So Tim wanted to be part of the Branch User Forum. He 19 was quite vocal. I'd conversations with him. 20 I understood, you know, some of his concerns, some of 21 his frustrations. And we had perfectly decent 22 conversations and I think -- I can't remember what 23 happened, but then I think I stopped communicating with 24 him because the messages to myself became quite 25 aggressive. So I would get texts messages on 138 1 a Saturday, you know, completely disagreeing with some 2 of the, you know, the information that I was telling 3 him, and then that was the extent that I stopped my 4 communication with him. 5 Q. What do you recall of the concerns that he was raising? 6 A. I can't remember the specific time but I think, you 7 know, it was obviously -- he wanted to make some 8 improvements to the way the Post Office was operating, 9 which was absolutely fine. I think he'd had an IT 10 background, I think, from what I can recollect, and 11 I think he wanted to make some, obviously, some 12 suggestions and improvements. I think that's what his 13 general sort of response was about. 14 Q. If it's suggested that he was excluded from the user 15 forum by Angela van den Bogerd, would you agree or 16 disagree with that? 17 A. I think I'd probably partially agree. I think if there 18 were some concerns, you know, constructive criticism is 19 absolutely fine. I think there was some -- I don't 20 know, if it was going to be a challenging discussion, 21 you'd want to make some outputs. I think I'd probably 22 agree with that statement. 23 Q. Looking back now at how serious everything in fact was, 24 do you think it was a mistake to exclude him from that 25 forum? 139 1 A. I don't think anybody with -- should be excluded if, you 2 know, if they've got suggestions to make. I think there 3 was probably some disagreements over behaviours. 4 Q. At paragraph 92 of your witness statement you also refer 5 to feedback sessions. Are they separate to the Branch 6 User Forum, or are they something different, or ... 7 A. Yeah, so this was separate. So on the back of -- you 8 know, in order to validate, there was some of the 9 findings. Myself and Anne, who worked with me at the 10 time, in order to sort of gauge what some of the issues 11 were, there was a number of people around the business 12 that we spoke to, and postmasters. So this was on the 13 back of the thematic issues that had come out in terms 14 of training and support. So it was very much about, you 15 know, what could we do differently? What ideas have you 16 got? Et cetera, et cetera. 17 Q. You refer to a range of stakeholders. Are you able to 18 tell us -- give us a little bit more detail? 19 A. Yeah, so it would have been postmasters. Basically 20 anybody who had direct intervention with postmasters. 21 So I spoke to Network Business Support Centre advisers, 22 contracts advisers, field support trainers and auditors, 23 people in Product and Branch Accounting, security 24 advisers, the National Federation of SubPostmasters. 25 People who had that interaction themselves. 140 1 Q. You mentioned the NFSP. Were there any other unions, 2 such as the Communications and Workers Union? 3 A. No, it was just the National Federation of 4 SubPostmasters. 5 Q. Any reason why it was them in particular? 6 A. I think there was discussions internally around, you 7 know, the National Federation of SubPostmasters was the 8 recognised union of the postmasters. I don't think the 9 Post Office recognised the CWU formally as the union of 10 postmasters, therefore we weren't encouraged to talk to 11 them. 12 Q. The final topic that I have is the Executive 13 Correspondence Team. That seems to be from 2015, 14 I think, when you were head of Branch and Customer 15 Support. 16 A. Yeah. 17 Q. Can you give us a flavour of the kinds of correspondence 18 that subpostmasters and their assistants or managers 19 made in relation to bugs, errors and defects in Horizon, 20 how early were they corresponding on those issues in 21 your time? How often? 22 A. I can't remember any specifically. I don't know if 23 there was a process that was set up with Legal Services 24 because of the potential litigation that we almost 25 didn't deal with those, if that makes sense. I think it 141 1 was one of those where if that was where it was flagged, 2 I think they were put to the Legal Department. I can't 3 be 100 per cent sure, but I think that that -- based on, 4 obviously, what was going on at the time, I think it had 5 been agreed that that's the process that would follow. 6 So we didn't attempt to respond to those ones. That 7 would go to Legal Services. 8 Q. Typically, in relation to correspondence, how would you 9 interact with the CEO or other executives? I mean, did 10 you have a direct line to them? Would you raise 11 significant issues with them? 12 A. Yeah, you could ask to speak to, you know, anybody at 13 whatever time. They needed to be aware, especially if 14 they'd been written to, because it was usually that 15 person would say "Can you respond to that one?" Because 16 sometimes they would go to their personal email address 17 which they'd pick up, and then it would end up being 18 back with the correspondence team, or it would be via an 19 MP or whatever. But yeah, you could approach any of the 20 board members. And, you know, if there was a particular 21 one that -- in the main, they were happy that you were 22 dealing with those issues, but if there was 23 a particularly sensitive one then the door was always 24 open to have that discussion. And especially if you 25 were writing back in somebody's name, they had to sign 142 1 that off. 2 Q. I think you've said that typically, the letters about 3 bugs, errors and defects would go to the legal team? 4 A. I think they did, yeah. 5 Q. Was that an instruction from somebody? 6 A. I think that probably would have come from Legal 7 Services. So Jane MacLeod and her team, I think it 8 probably would have been, at the time. 9 Q. So do you recall an instruction from them that if people 10 are communicating about bugs, errors and defects, they 11 should send them to them, rather than to deal with them 12 within your team? 13 A. I can't be 100 per cent sure, but the fact that I can't 14 remember dealing with any would suggest that that's what 15 happened. That's my recollection. But I can't be a 16 hundred per cent sure. 17 Q. Thank you. Finally, could we just have a look at 18 paragraph 146 of your statement so WITN06160100. 19 Page 49. It says: 20 "My experience of working in the Post Office was 21 that it operated within a strict risk control framework 22 and there were processes in place for making decisions. 23 Any change to policy, approach, request for funding, 24 etc, had to be signed off at the highest levels, 25 sometimes including a shareholder, and it did not appear 143 1 that individuals could make decisions in isolation or 2 outside of their remit. Before the separation of Post 3 Office from Royal Mail Group, there were internal 4 processes for approvals, and then this would go to the 5 Royal Mail boards for further approval. Once decisions 6 had been made and strategies agreed, this then filtered 7 down into individual objectives at every level in the 8 organisation. It wasn't an environment where you could 9 just do what you wanted if you felt like it." 10 Was it an environment where it was difficult to 11 speak out? 12 A. Um, I think it depended on the individual. I personally 13 didn't feel as though -- you know, if I'd an issue, 14 I felt that I could raise it. I think some people felt 15 they couldn't, for whatever reason. There was the 16 whistleblowing line. There were sensitive cases that 17 people did speak out that, obviously they went to the 18 Executive Correspondence Team, that I was privy to, 19 because obviously it was my team that they were 20 responding to. So people were raising issues. People 21 were encouraged to say what they think. Whether it was 22 agreed with is a different matter, but I, on a personal 23 level, didn't feel like I could not raise something. 24 Q. We've looked at, for example, the Second Sight report 25 that wasn't shared with you. Was there, in respect of 144 1 bugs, errors and defects, information that was kept from 2 you, do you think, intentionally? 3 A. I don't know. And I've reflected on this, obviously, 4 since you sent the information. And, you know, when 5 you're asked a question in the statement, "Well, why 6 were you selected to do the Branch Support Programme?", 7 the positive side of me goes: because I thought I had 8 the right skills to do the job. Having seen some of 9 this stuff, the cynical part of me goes: well, was 10 I picked because I would do what I was told? I don't 11 know. I trusted the people that I worked for. 12 I accepted the information that was in good faith. 13 So I didn't -- I don't know what they kept from me. 14 I wouldn't like to think that we were deliberately doing 15 that, but I couldn't -- unless you asked them. I don't 16 know. 17 MR BLAKE: Thank you very much, Ms Peacock. I don't have 18 any further questions. 19 I think there is a small number of questions. 20 SIR WYN WILLIAMS: Yes, I am anxious that the transcriber 21 shouldn't be asked to continue unless it really is just 22 five or ten minutes, maximum. All right. 23 MR JACOBS: Sir, I think I'll be five minutes. 24 SIR WYN WILLIAMS: Nobody else? 25 MR BLAKE: Ms Page? 145 1 MS PAGE: I mean, if I were 10 minutes, then -- I don't 2 think I will be but -- 3 SIR WYN WILLIAMS: I think we will just take a few minutes' 4 break so that the transcriber can just have a short 5 rest, and she's not very well. We'll come back again at 6 quarter past, and then we'll be as swift as we can be. 7 How about that? 8 MR BLAKE: Thank you. 9 (3.06 pm) 10 (A short break) 11 (3.16 pm) 12 SIR WYN WILLIAMS: Mr Jacobs. 13 Questioned by MR JACOBS 14 MR JACOBS: Thank you, sir. 15 Ms Peacock, good afternoon. I represent 156 16 subpostmasters, who instruct Howe+Co, who instruct me. 17 You told Mr Blake earlier on this afternoon that a lot 18 of your career was spent providing support to 19 subpostmasters; is that right? 20 A. Yes. 21 Q. You also said, when you were asked about unprofessional 22 conduct of auditors, you couldn't remember any examples? 23 A. Not that had been raised to me. 24 Q. I want to ask you about within of our clients, Shazia 25 Saddiq. I don't know if you've followed the Phase 1 of 146 1 the hearings when the subpostmasters gave evidence last 2 year? 3 A. No. 4 Q. Well, her evidence was read in to the record on 16 March 5 2022, and just as a whistlestop summary, she was 6 a subpostmaster with three branches in Newcastle, and 7 she paid over £10,000 in relation to alleged shortfalls. 8 Post Office demanded another £20,000 off her in relation 9 to further alleged shortfalls, and she was a victim of 10 cyber fraud as a result of the Horizon System being 11 vulnerable, she says, to hackers, and the Post Office 12 held her liable for the recovery of that theft by third 13 parties in the sum of £33,000. 14 A. Is this the MoneyGram one? 15 Q. The MoneyGram one. 16 A. Right. 17 Q. Do you remember? 18 A. I do, yes. Yes. 19 Q. Shall we go, then, to Ms Saddiq's statement, and that is 20 at WITN02230100. Page 7 of 16, please. Thank you. 21 That's on screen. So if we look at paragraph 32, you'll 22 see, as you correctly say, the MoneyGram transfer? 23 A. Yes. 24 Q. She was initially told that only her branch was affected 25 but later it was accepted that it affected 11 other 147 1 branches, she says. My client's evidence is, at 2 paragraph 34, that the Post Office wrote to her and told 3 her that it would be holding her responsible for the 4 losses calculated at nearly £34,000. 5 A. Mm-hm. 6 Q. So if we could then go to paragraph 35, which is the one 7 I particularly wanted to ask you about. So she says 8 that on 20 August 2014, she met with Rachel Lax and you, 9 and you described yourselves as Post Office internal 10 investigators. You reviewed her personal finances in 11 detail to determine what payments she could afford to 12 make towards this sum of money that was stolen, she 13 said, while at the Horizon System. So do you recall 14 that meeting? 15 A. I do, actually. I can't recall -- I think I would have 16 said "I'm investigating the issue." I don't think would 17 have said "I'm an investigator", but I do remember the 18 meeting, yeah. 19 Q. Well, then, we'll move on to what Ms Saddiq has to say 20 about the meeting, which is over the page at paragraph 21 36, please. So she says: 22 "This was a deeply humiliating experience, as they 23 were looking through all my personal bank and other 24 records. And this was done in a public area of Holiday 25 Inn Hotel. As they looked at my records, they made 148 1 comments about where I bought my children's shoes from. 2 This was none of their business. I was also embarrassed 3 as I lived very humbly; I spent as little as I could on 4 myself and maintaining my family, so it was humiliating 5 to have strangers pore over my personal accounts in 6 public and see how little I spent on myself and my 7 children." 8 I want to ask you some questions about that. Why 9 was the meeting held in a public area in a hotel? 10 A. Because that's where she requested it to be held. 11 Q. We understand that this is where you suggested it was to 12 be held? 13 A. I didn't know the area at the time, and I asked to meet 14 at her branch, and this was where she suggested that we 15 meet. 16 Q. Did you think it was appropriate to ask her to go 17 through personal detail in a public area? 18 A. In hindsight, probably not. At the time she didn't 19 mention it, but then I guess she probably -- if she felt 20 that she couldn't raise it to me. I'm really 21 disappointed that I've had that effect on her. I didn't 22 know that. 23 Q. If we go to paragraph 37, please, you'll see she goes on 24 to say: 25 "At the end of this humiliating meeting where it was 149 1 made clear that I had no money to pay the Post Office to 2 make up for the crime (the MoneyGram cyber attack) that 3 had been perpetrated against my Post Office, the 4 investigators said they would put a charge on my 5 properties. They said this as though they were doing me 6 a favour." 7 Do you recall that? 8 A. There was some discussion internally about the whole 9 MoneyGram issue anyway, in terms of the number of 10 branches that were affected. There was sort of 11 a decision around who would be held liable, what the 12 approach would be. We did talk about how her business 13 was performing, and her income levels. I'm not going to 14 deny that. I knew that that was an approach that the 15 Post Office could take. I don't think we ended up going 16 down that route. That's not my interpretation of the 17 meeting, but if that's what she said, then that's what 18 she said. 19 Q. You've said just now that -- and the transcript keeps 20 jumping around -- you've said that you regret that it 21 had this effect on her? 22 A. Mm. 23 Q. Do you regret the way you and your colleague conducted 24 this meeting, in light of her evidence now? 25 A. If that's how it made her feel, then yes. 150 1 Q. Can we go to paragraph 39. She subsequently had 2 a breakdown as a result of the pressure that the Post 3 Office were putting her on. 4 A. Okay. 5 Q. The question that Ms Saddiq wants me to ask is: do you 6 accept that this was insensitive and unprofessional as 7 a way to behave towards a businessperson? 8 A. Yes, if that's the -- yeah. 9 Q. Now, you said earlier on in your evidence that you 10 weren't aware of any complaints that had been made in 11 relation to audits. I just want to ask you; a number of 12 our clients gave evidence in the Phase 1 hearings and 13 they said that the Post Office adopted a tactic, 14 seemingly, of humiliating them in public. Shahnaz 15 Rashid and Heather Earley talk about surprise audits 16 where auditors marched into their branches that were 17 full of customers, and closed the branches down, and 18 Katherine McAlerney talks about "aggressive questioning" 19 of her in front of her customers. 20 Are you aware of auditors and investigators adopting 21 these tactics when there investigating subpostmasters? 22 A. I think, when we did the review on the Second Sight, 23 I think there was the feedback that some of the security 24 team were maybe being a bit too masculine in the 25 approach, and aggressive in terms of, you know, as you 151 1 delve into some of the feedback and ask people about 2 their experience, that did come to -- you know, there 3 was a feeling, but I didn't have any specific -- 4 I couldn't give you a branch, for example, to say this 5 one was raised with me. 6 Q. You, I think, were taken by Mr Blake to paragraph 129 of 7 your statement. I don't think we need to turn it up. 8 Well, I know you've got it, because I can see it there, 9 so perhaps we will turn it up. You say: 10 "Even when the claims about Horizon started to be 11 known within the business, the message coming from the 12 business was that the system was not capable of 13 impacting the accounts." 14 The question that my clients have asked me to ask 15 you is, looking back now -- and I know, just 16 interjecting, that you talked about comments where 17 people were saying that subpostmasters were making noise 18 and you said there was a cynical attitude. Looking 19 back, do you accept that the Post Office's refusal from 20 the top to countenance the possibility of errors led to 21 a high-handed and unprofessional treatment of 22 subpostmasters by auditors and investigators? 23 A. I didn't experience that personally, but I could see how 24 that was correct in some cases. 25 Q. That the view from the top led to the mindset of the 152 1 investigators in this way? 2 A. Um, yeah, I think it was -- you know, a dismissive 3 approach will filter down. 4 MR JACOBS: I just need to ask to see if I've got any more 5 questions to ask you. Thank you. I haven't got any 6 further questions. 7 SIR WYN WILLIAMS: Ms Page? 8 Questioned by MS PAGE 9 MS PAGE: Thank you. I also represent some subpostmasters. 10 You've told us that you were aware of the 11 discontinuance of prosecutions? 12 A. Mm-hm. 13 Q. End of 2013 going into 2014? 14 A. Yes. 15 Q. How did you come to know about that? 16 A. That was just discussed as part of the Branch Support 17 Programme, the conversations with Angela. We were 18 obviously working with security and Legal Services quite 19 heavily as part of that -- as the programme saw, I was 20 made aware that, you know, it was pausing, given 21 everything else that was going on. 22 Q. When you say "everything else that was going on", what 23 do you mean by that? 24 A. So, you know, obviously the Second Sight review, the 25 claims that were being made. That kind of stuff. The 153 1 view that I got was, you know, that it wasn't 2 appropriate to continue prosecuting, and that was 3 a message which you accepted. 4 Q. When you said it just now, you said "pausing". Was that 5 something you understood at the time? Was that the way 6 it was being expressed, or was it going to be stopped 7 completely? 8 A. I don't think anybody had made a decision. I knew we 9 weren't going to, but I didn't know -- I didn't get the 10 impression -- I didn't know whether it was permanent at 11 the time, or whether it was pausing, or whether it was 12 stopping. 13 Q. When you had those conversations, do you remember if 14 that came from Angela or from Security, or both? 15 A. I think it came from both. 16 Q. Now that you've seen the documents from Mr Simon Clarke 17 you've drawn a line between that and the discontinuance 18 of prosecutions. Can you just help us with your 19 reasoning there and your conclusion? Why have you drawn 20 that line? 21 A. What do you mean by "draw the line"? 22 Q. You said, "Now I've seen the documents from Mr Clarke 23 I can see why they stopped the prosecutions". What 24 makes you say that? 25 A. Well, because I think that they hadn't disclosed the 154 1 fact that actually bugs could do it. So I can now see 2 the reason why the prosecutions had stopped: because 3 there was the potential that the prosecutions were 4 unsound. 5 Q. Then, during those conversations with Ms van den Bogerd 6 and the security people -- by which you mean presumably 7 Mr Posnett, do you? 8 A. No, Mr Scott. It will be John Scott who was head of 9 Security at the time. 10 Q. John Scott. Did either of them ever mention to you the 11 idea that there might be a litigation risk that needed 12 to be notified to POL's insurers? 13 A. No, I can't remember that. 14 Q. Just sticking with Mr Clarke's advices for a moment, in 15 your pack from the Inquiry -- you've had two, haven't 16 you? 17 A. Yes. 18 Q. You've had the one which relates to Mr Jenkins and the 19 one which relates to the minuting of the weekly Horizon 20 meetings. 21 A. Yes. 22 Q. That second one, about the minuting of the Horizon 23 meetings, albeit you didn't see it at the time, were you 24 aware at the time that there was an issue around the 25 minuting and the keeping of the minutes? 155 1 A. I think when, obviously -- because I think Bond 2 Dickinson undertook the note-keeper roles. I think 3 there was a paralegal involved in the weekly meetings, 4 and I think when -- because it varied week on week. 5 I think it was mentioned at the start why the paralegals 6 had basically to make sure that it was fully documented, 7 and I think that was the extent of which it was 8 introduced. 9 Q. So you weren't aware at any time that there was an issue 10 around the keeping of those minutes or the keeping of 11 them securely? 12 A. No. 13 Q. The representatives from security. Second Sight had 14 found at this stage that there was a focus in security 15 on asset recovery solutions without further establishing 16 the underlying root cause of the problem. 17 A. Mm-hm. 18 Q. Is that something you would have recognised at the time 19 if you had have been told about it? 20 A. Sorry, what do you mean by that? 21 Q. If you'd have read that Second Sight report which had 22 that finding in it, is that something that would have 23 chimed for you at the time, knowing the people that you 24 knew from Security, Dave Posnett, Rob King? 25 A. Yes. 156 1 Q. Then on Mr Griffiths, after that meeting that we've 2 looked at the note of, did you hear any more about him 3 from Ms van den Bogerd? 4 A. So I think they attended the funeral of Mr Griffiths. 5 I think there was -- I can't remember if Angela 6 attended. I think Anne Allaker did attend on behalf of 7 Post Office. And they were talking to the family. 8 I don't know the ins and outs of the conversations. And 9 that was the extent of the knowledge on that particular 10 case. 11 Q. So you didn't hear anything about a settlement made to 12 the family? 13 A. No. I presume it might have gone through mediate -- one 14 of the mediation cases, potentially, but I can't confirm 15 that. 16 Q. On the Detica report, would you accept it was covering 17 some of the ground that you were given to look at in the 18 Branch Support Programme? 19 A. Yes. 20 Q. Was it given to you with that in mind, as it were? 21 A. I think it was. I think it was to sort of -- I think 22 the Detica report, it was -- they were trying to do 23 a business case to actually progress Detica into the 24 business. And I think I saw it to see if there were 25 themes that we were picking up. But yeah, I think it 157 1 was just to substantiate some of the issues. Some of 2 the stuff in the Detica report wasn't surprising. 3 Q. Would you accept it was quite a critical report? 4 A. Yes. 5 Q. In light of that, is it perhaps a bit surprising that it 6 wasn't mentioned in any of the Branch Support Programme 7 documentation? It wasn't discussed more widely? 8 A. In what way? The issues? Because the Detica report 9 didn't seem to have a lot of recommendations. 10 Q. The issues that they found, the problems that they 11 found? 12 A. Um, I think we probably did discuss them. Whether it's 13 been documented or minuted, I'm not sure, but we were 14 definitely aware of them. 15 Q. Just finally, with the benefit of hindsight, and 16 I appreciate what you've been quite sort of careful 17 about thinking about things in terms of at the time and 18 hindsight, this is specifically a hindsight question. 19 Do you think that, given that the Second Sight review 20 was sort of rather filleted for you, if I can put it 21 that way, that it -- the bits that were filleted out and 22 given to you for the Branch Support Programme to look 23 at, do you think that was really a sort of a sop from 24 POL Management, to seem as if they were taking the 25 concerns seriously? To seem as if they were acting on 158 1 Second Sight's recommendations whilst actually blocking 2 or impeding those investigations? 3 A. I can see how you make that interpretation. I think my 4 perspective of it, I felt, you know, there was a genuine 5 need and requirement to change some of the things that 6 were given to us. I genuinely believed that that wasn't 7 paying lip-service. I think in some ways, the Second 8 Sight report in that aspect gave momentum to some of the 9 feelings that, you know, were known. I don't think the 10 issues that we were looking at were actually paying 11 lip-service. I think people, you know, genuinely wanted 12 to change those areas. I don't think it was as 13 a distraction, not -- I don't know why they didn't 14 consider the Horizon stuff as seriously as they did, but 15 I genuinely believed that they wanted to change things 16 for the better. 17 Q. At the time? 18 A. At the time. 19 Q. Looking back? 20 A. I don't ... the cynical part of me says yes, maybe 21 a little bit, but I think it was too much hard work for 22 it to completely be, like, dismissed and a sop. I think 23 the genuine -- you know, to improve things for 24 postmasters was there. Whether you want to accept that, 25 that's entirely up to you. I personally believe that 159 1 the genuine belief was there to do it. Given some of 2 the, you know, not everybody in -- those stakeholders 3 mentioned on that agenda I think genuinely did believe 4 that we should change things. I think some of them did 5 pay lip-service to the programme. And part of what we 6 were trying to do, we came across challenging 7 conversations with people to try to get them to believe 8 that. I think we wouldn't have gone through some of 9 those arguments and disagreements had we not genuinely 10 believed that we absolutely had to change the training 11 and support for postmasters. 12 MS PAGE: Thank you. Those are my questions. 13 SIR WYN WILLIAMS: Thank you for providing a detailed 14 witness statement. Thank you for coming to give oral 15 evidence. 16 THE WITNESS: You're welcome. 17 SIR WYN WILLIAMS: Right. 10.00 tomorrow morning, Mr Blake. 18 MR BLAKE: Thank you very much, sir. 19 (3.36 pm) 20 (The hearing adjourned until 10.00 am the following day) 21 22 23 24 25 160 I N D E X ELIZABETH ANNE ALLAKER (affirmed) ....................1 Questioned by MR STEVENS ......................1 Questioned by MR STEIN .......................54 GAYLE PEACOCK (affirmed) ............................58 Questioned by MR BLAKE .......................58 Questioned by MR JACOBS .....................146 Questioned by MS PAGE .......................153 161