1 Thursday, 2 March 2023 2 (10.00 am) 3 MS KENNEDY: Good morning, Chair. 4 SIR WYN WILLIAMS: Before you begin, is the transcriber in 5 the room? Probably not. 6 MS KENNEDY: She is indeed. May I call Mr Brian Trotter. 7 BRIAN TROTTER (affirmed) 8 Questioned by MS KENNEDY 9 MS KENNEDY: Good morning, Mr Trotter. My name is Ruth 10 Kennedy and I ask questions on behalf of the Inquiry. 11 Could you confirm your full name, please? 12 A. My full name is Brian Alexander Trotter. 13 Q. You gave a witness statement to think which is at 14 WITN00980100. Do you have that statement in front of 15 you? 16 A. I do, yes. 17 Q. If you turn to page 22, is that your signature there? 18 A. It is, yes. 19 Q. It should be dated 4 January 2023; is that right? 20 A. That's correct, yes. 21 Q. Have you read through this statement recently? 22 A. I have, yes. 23 Q. Is it true to the best of your knowledge and belief? 24 A. It is, yes. 25 Q. That statement is now in evidence. Everything that 1 1 I ask you will be supplementary to that. 2 Could you start by telling us what did you do 3 before you joined the Post Office? 4 A. I actually joined Royal Mail Group in 1980, so before 5 then I was in the Royal Navy for six years. When 6 I joined the Post Office in 1980, at that time it was 7 classed as Post Office Telegrams. So I was there from 8 1980 to 1982 and made a decision to move into the 9 counter side of the Post Office. So I worked at the 10 counter for a couple of years -- well, five years 11 actually between -- 12 Q. When did you do that? When did you move to Counters? 13 A. From 1982 I moved to the counter and I worked on the 14 counter for about five years to 1987. I was then 15 promoted to assistant branch manager at the branch 16 I worked at and then an opportunity came up and, forgive 17 me, I'm not completely accurate with dates here but 18 I think around 1990 I moved up north to a branch -- very 19 well north in Scotland actually Peterhead and relocated 20 up there with my family until 1993. 21 There was a restructure of the Post Office at that 22 time so I moved back down south to the central belt and 23 I was appointed to -- it was a new concept in the Post 24 Office, I was a regional helpline manager from 1993 to 25 '95. 2 1 From there, I think my witness statement covers 2 pretty much the rest of my career. 3 Q. You stayed at the Post Office until 2020; is that right? 4 A. Yes. 5 Q. Between 1995 and 2005 your role was an area manager 6 role? 7 A. That's correct, yes. 8 Q. Could you tell us a bit about what that involved. 9 A. Primarily, you're responsible for looking after 10 a geographical patch, so it could be anywhere between, 11 you know, couple of hundred offices at that time, close 12 to 1,000 maybe and the responsibility was to try and 13 make sure that every office in that part, you actually 14 went to see them at least once a year. More 15 concentration was given, obviously, in the bigger 16 branches where there was more issues, if you like. 17 So there was more face-to-face contact in the 18 bigger branches, as I think I've said in my statement, 19 than the smaller branches. 20 Q. Shall we turn that up. So WITN00980100 and if we go to 21 page 2. 22 A. Yes, I've actually said there "dependent on branch 23 size". 24 Q. Yes. So I think you are looking at paragraph 5, which 25 says: 3 1 "Initially, this role included visiting branches 2 as determined by the Head of Retail network usually once 3 a year and dependent on branch size I would also manage 4 sites' adherence to his standards. These could be done 5 by face-to-face visits, telephone or written 6 correspondence. This management activity would be 7 triggered by a wide range of issues, including customer 8 complaints or postmasters asking for assistance, which 9 was mainly via the National Business Support Centre 10 helpline." 11 So you generally go to visit the branches once 12 a year but you would also go when a management activity 13 triggered it; is that right? 14 A. Yes. So, for example, if an enquiry or complaint came 15 in about a branch then you would need to go and speak to 16 postmaster and get their version of events. Obviously, 17 that was important. I'm not being completely correct in 18 my terminology there about the helpline. I think in 19 those days there would have been some sort of helpline 20 but, forgive me again, I'm struggling to remember what 21 kind of structure was in place. But, generally 22 speaking, any escalations for branches came through some 23 sort of centre, whether that be regional centres or, you 24 know, later on in my career it was generally centre of 25 the business. 4 1 Q. How often would you visit branches because there have 2 been some kind of issue that had come to you through 3 management? 4 A. It's really difficult to remember actually. Thinking 5 back about this, the whole programme was driven by the 6 number of branches in your area, the size and I guess, 7 potentially, in the number of problems. That was the 8 rationale. You know, if there's a bigger branch then 9 potentially there could be more problems. The smaller 10 branches that were in the rural part of the network, 11 less footfall, less customers; generally they created 12 less problems. 13 But that was the sort of rule or the measure that 14 we used to determine or drive the visit programme. 15 Q. If we could turn back to your statement and scroll down 16 to paragraph 6, please. It says there that: 17 "This role did not deal with quality assurance or 18 training. However, I supported the rollout of Horizon 19 by supporting postmasters with their first balance post 20 implementation of Horizon. Agents would already have 21 some training, but I would go in person to the site and 22 'hand hold' the postmasters through the Horizon 23 balancing process in the first week." 24 Can you explain to us what that was like or what 25 your experience was when Horizon was first rolled out? 5 1 A. Yes. So when Horizon was first rolled out, I think it's 2 been mentioned earlier in the Inquiry, the Retail 3 Line -- or area managers, as it's known -- were 4 responsible for supporting the first balance or the 5 first follow-up balance. So, essentially, what that 6 meant was I'd make contact with the postmaster, probably 7 couple of days before the balance was due, to let them 8 know I was coming, we'd just have a general commercial 9 about how things were going. 10 I would ask them if there was any issues you know 11 that they wanted to speak about, I could potentially 12 flag up, because they could be flagged back up to 13 a central point. 14 From there, on the day the balance was due, 15 I would arrive couple of hours earlier before it was 16 due. We'd just talk about, again, how things were 17 going, we'd talk about the work aids that were 18 available, whether they were using them. When the 19 branch closed for business, then we would systematically 20 work through the balance process until its completion 21 and that could take anywhere between a couple of hours, 22 in as much as it could fall into the following day. It 23 really depended on, I guess, how well the new -- sorry, 24 the postmaster had grasped the operation of the new 25 system. 6 1 Q. Did you deal with anyone who was struggling with the 2 operation of the new system? 3 A. Yes, absolutely. I think again, depending on where the 4 branch was, how many staff were employed in the branch. 5 You know, for example, if it was a rural branch it might 6 be one person running the branch and they obviously had 7 to try to get their head round this big change, you 8 know, get used to using IT. 9 So, in my mindset, I had to make allowances for 10 that and say, right, okay, if it was me, how would 11 I actually systematically work through this process to 12 make sure that when I did actually leave the branch they 13 would feel capable and equipped for the following week. 14 I mean, what would happen is, you know, if you 15 completed the process or the balance and you felt in 16 your mind that there was still some issues, from memory 17 we had like a hot desk in the Retail Line, we could flag 18 that back up to an individual and say, "Look, although 19 the balance has gone reasonably well, this may require 20 another visit, it may require another support visit to 21 help them through the balance". That was kind of how it 22 worked. 23 Q. How common was that, what you just described, flagging 24 something for further assistance? 25 A. I mean, I've given this a great amount of thought in 7 1 detail and, given -- because, in the main, my 2 responsibility was visiting branches or going to 3 branches in Scotland, so you had the geographical 4 challenge. In addition to that, in Scotland you do have 5 a lot of rural branches in isolated locations. 6 I couldn't put a figure on it or a number on it but 7 I would say if you asked me a general question I would 8 say that it would be more challenging for rural branches 9 and maybe there's only the postmaster there or maybe one 10 other member of staff. 11 Bigger branches that could consult with each 12 other, you know the staff and the postmaster, they 13 seemed to have a better idea of how to use the IT and 14 a better grasp, actually, working their way through the 15 balance process. 16 Q. Focusing on the rural branches then, which you said 17 tended to have more problems, was it quite common then 18 for subpostmasters in that situation to say they were 19 struggling at this time? 20 A. I would think so when you were there, you would 21 encourage them to be open. You know, it wasn't in 22 anybody's interest to leave that branch, certainly not 23 in my nature to walk away from somebody and say, "Look, 24 you've had, you know, your one balance support visit". 25 My nature is always to try to be helpful and supportive. 8 1 So if I thought that there was any indication or 2 any evidence, actually, that they were going to struggle 3 I would have been putting it back up the line to say 4 "Look, we really do need to continue maybe putting in 5 another support visit". The challenge of that was 6 obviously, because of the size of the programme, you 7 know, a visit schedule had already been put in place but 8 we could work within that. You know, you could go back 9 to the branch outside of the balance day and spend some 10 time with the postmaster and just maybe go through the 11 work aids again, you know the support material, just to 12 try and help them along. 13 Q. Turning back to your statement, if we could turn over 14 the page to paragraph 7, please, you say there, at this 15 stage: 16 "The Contracts Manager for each particular area 17 would have dealt with any allegations or suspicions of 18 false accounting and therefore as Area Manager, I had 19 very minimal dialogue on interventions or suspensions 20 although I may have got involved with meeting with 21 a postmaster after red flags were raised via escalations 22 from support teams or field intervention teams." 23 When would a red flag be raised and what would 24 that involve? 25 A. I mean, there was certain paperwork or materials that 9 1 came from the centre, that didn't go through the 2 contracts team. It was more appropriate to have a field 3 visit. So, in those days, before we actually moved to 4 the next restructure, the area manager was responsible 5 for going out to actually speak to the postmaster. 6 I think it was important to get, you know, both sides of 7 the story, get their version of events. What I used to 8 find from experience was that, if you spoke to 9 a postmaster, in those days when you actually went to 10 visit offices, it was more of an informal discussion. 11 You could sit down and go through things logically. 12 Again, if there was anything that they said during 13 that informal meeting, you could push it back up the 14 line. It didn't mean to say that when you got the 15 paperwork that was the end of it, you know. It wasn't 16 an automatic default to "Right, we think you've made 17 a mistake, you must pay the money". 18 Q. How often were red flags raised or how often were you 19 doing that kind of job or role? 20 A. I can't really say. It's difficult to determine or 21 estimate, actually, because, during that time -- I mean, 22 it was early days of Horizon. There was a new 23 structure. I think -- I haven't actually mentioned in 24 my statement until, I think, it's the second last line, 25 in 2001. A restructure took place in 2001 where we had 10 1 dedicated contracts managers and, generally, although 2 I wasn't one at that stage, generally they took 3 responsibility for those red flags. 4 Our role was to continue working with the agent to 5 make sure business standards were being maintained, 6 there wasn't too many customer complaints, that sort of 7 thing. 8 Q. So did you feel that an area manager role was more of 9 a supportive role, whereas -- sorry, go on. 10 A. Sorry, that was the impression I got, yes, certainly, 11 and again following that restructure. The focus of the 12 business at that time was to allow area managers to 13 concentrate on, you know, either building new 14 relationships with new agents or continue developing 15 relationships with existing agents. 16 Q. You then moved to a role as a contract manager between 17 2004 and 2006, contracts and service manager, and then 18 that in 2006 changed to contract adviser, but it was all 19 broadly the same role; is that right? 20 A. Yes, broadly speaking, it was the same role. It was 21 looking after all aspects of the agents' contract. The 22 only difference was that again -- because another 23 restructure took place in the Post Office in 2004 where 24 they split sales and service. So to address that, the 25 team that I worked in between 2004 and 2006, I had line 11 1 management responsibility in the area that I was 2 responsible for. I had couple of area intervention 3 managers and an area performance manager. 4 Q. Who reported in to you? 5 A. Yes. 6 Q. Your geographical scope covered about 1,000 branches; is 7 that right? 8 A. It was but in those days they were still recutting 9 areas. Again, I've thought about this in a bit more 10 detail. Possibly, at that time, I may have been 11 covering Northern Ireland as well. So my area 12 geographically could have been possibly as big as -- 13 I think guessing between 1,600 and 1,700 branches. But, 14 again, a realignment took place as the structure 15 developed and embedded itself to make it a fairer 16 balance of branches. 17 Q. As a contract manager, your role did involve audits. 18 I know you say in your statement you didn't organise 19 them but can you tell us how you were involved in 20 audits? 21 A. So in my role as a contracts manager -- well, just to go 22 back a step, generally speaking, the audits would be 23 requested and planned by the centre. So they would be 24 unannounced, unless it was -- you know, the only other 25 audit out of that sphere was audits that followed a new 12 1 postmaster being appointed. That was usually sort of 2 nine months to a year after. 3 But to answer your question, yes, an audit would 4 be scheduled from the centre. I would become involved 5 when the lead audit was ready to report their findings. 6 So that could be, you know, a couple of hours after the 7 audit started or it could be at the end of the day. It 8 really depended on the complexity and the findings. 9 Q. How often were you having to go and speak to 10 subpostmasters and inform them of the results of 11 an audit? 12 A. Well, if the audit went -- you know, if the audit was 13 done and there was no issues, then the branch would be 14 allowed -- I mean, they would phone me and say "Look, 15 Brian, the audit's been done, we've been here. There's 16 no issues, we're going to reopen the branch". I would 17 only really be contacted urgently if there was an issue 18 or a problem at the branch concerning the balance. 19 Q. If there was a problem concerning the balance you would 20 meet with the subpostmaster; is that right? 21 A. That would be later on. On the day of the audit -- 22 I mean, there's sort of three steps. When the audit was 23 taking place, we would work through a checklist of quite 24 a lot of -- you know checking a lot of detailed 25 documents. You know, we would be checking, like, call 13 1 logs for the NBSC. We'd be checking to see how the 2 training had gone. We'd be checking to see how the 3 application interview went. 4 So really what I'd be doing, I would be logically 5 working through a list of things that had happened 6 before the audit took place, so that when I eventually 7 spoke to the lead audit or when I spoke to the 8 postmaster, I would be fully appraised of what actually 9 happened before the audit. 10 Q. If we could turn up your statement again, WITN00980100 11 -- thank you -- and if we could turn over the page to 12 page 4, please. 13 A. Okay, yes. 14 Q. Just scrolling down to paragraph 11, you set out in 15 paragraph 11 what happens on completion of the audit and 16 you say: 17 "On completion of the audit I would speak to the 18 postmaster and go through the findings, I might have 19 also made reference to any checks that had been 20 undertaken during the audit such as calls logs, training 21 records, Horizon report and any other interventions, 22 which had been undertaken by the Contracts team." 23 That's the process you've just been describing; is 24 that right? 25 A. Yes, that's it. 14 1 Q. You then go on to say: 2 "It was usual at this stage for the postmaster 3 either to admit to misusing funds or to say that they 4 couldn't provide an explanation for the shortage." 5 A. Yes. 6 Q. Taking each one of those in turn, how usual was it for 7 the postmaster to admit that they had misused the funds 8 in this type of situation? 9 A. I think the percentage could be quite high. You know, 10 that conversation might even have taken place before 11 I spoke to the postmaster. I mean, I'm again wracking 12 my brain for examples. I do remember that an audit was 13 done at a branch and, forgive me I don't recall the 14 name, but it's pretty much as soon as they walked 15 through the door the postmaster had admitted to the lead 16 audit that he'd went to the cash and carry the day 17 before and he'd intended replacing the money. 18 It wasn't a massive sum of money but those sort of 19 the scenarios happened, where you might get 20 an explanation straight away or you could, in actual 21 fact -- I could go through my tick list, I could speak 22 to the postmaster, I could speak to my line manager, we 23 do further checks as a result of doing the audit and 24 still come to the conclusion that there was no 25 explanation. 15 1 Q. Yes, and when there was no explanation or the 2 subpostmaster said they didn't have an explanation, how 3 often did that happen? 4 A. I really think it depends on the time of day. I mean, 5 I could say that there could be quite a high percentage 6 of those where, you know, you've seen the audit report 7 and it's reported as unexplained. So an unexplained 8 audit, in my mind, needed further investigation if the 9 answer wasn't in the branch on that day of the audit. 10 Q. If we could turn over the page to page 5, please, and 11 looking at paragraph 16, which is at the bottom, you 12 talk there about where concerns are raise about the 13 functionality of the Horizon System. If a balance 14 couldn't be explained, did it ever cross your mind that 15 it might be a problem with Horizon itself? 16 A. Not really, no, because throughout programme the 17 messaging was, you know, the system was fit for purpose, 18 it was secure. I'm not technically minded when it comes 19 to front office, you know, processing packages but, in 20 my mind, I believed that it was operating the way it was 21 intended. 22 The reason I deducted that was because I had been 23 a user and, in my experience, and I can only talk about 24 my experience, it always worked as intended. 25 Q. In paragraph 16 you say: 16 1 "If concerns were raise about the functionality of 2 the Horizon System, then I would raise that with my Line 3 Manager and also the appropriate technology team for 4 input into the report. I recall that if there was no 5 obvious explanation for problems, I would monitor the 6 performance of the temporary postmaster to see if the 7 same problem continued. However, from my personal 8 experience there were no problems with temporary 9 postmasters." 10 So, in terms of your investigation that you 11 carried out, you basically passed it on to technical 12 people and your line manager; is that right? 13 A. Yes, I don't think I was equipped to actually come to 14 some sort of conclusion or decision about technical 15 matters like that. There was people that worked in the 16 business that were much better qualified than me that 17 could look at a situation or, if a postmaster said to 18 me, "Look, Brian, this has been going on for a while" -- 19 I mean, you know, to explain in its broadest terms, 20 I would say, "Look, I'm pulling my hair out here and 21 these losses are reoccurring". They'd ask for 22 an opinion, try and get some answers. 23 So the only place that I could actually go at that 24 time was put a red flag against it and pass it back up 25 the lined keep pushing until I got some answers. 17 1 Q. Did you trust the technical people to give you the right 2 answers? 3 A. I had to, yes, because I trusted their judgment but 4 I also knew I had known these individuals for a number 5 of years had worked -- not worked directly beside them 6 but worked in the same teams on other projects and other 7 things. So I trusted them to take ownership of the 8 problem and deal with it for me. That's pretty much 9 what I would say. 10 Q. That last line that of that paragraph about monitoring 11 temporary postmasters, if the temporary postmaster had 12 no problems, did you take that as evidence or a factor 13 to take into account in the fact that it was the 14 subpostmaster who'd made the mistake; it wasn't a system 15 error? 16 A. Well, I put that paragraph in my statement because when 17 I was thinking about it, and forgive me I don't remember 18 the year, but I do remember dealing with a case in 19 Glasgow, actually, where a postmaster -- and I think 20 this is maybe where I was an area manager at the time 21 possibly -- that he was concerned about ongoing losses 22 that were reoccurring. It was quite a big branch, 23 employed quite a few staff. It got to a point that the 24 shortfalls were so high a decision was made to suspend. 25 But following the suspension, one of our large 18 1 temporary subpostmaster companies took over the branch 2 and they put some very, very strict and rigid controls 3 in place and after about six weeks, or maybe longer than 4 that, they reported back to me to say that they'd found 5 a thief working in the branch and she'd been using the 6 postmaster's money to pay her bills. 7 Q. So was your assumption that if there was no problem with 8 the temporary subpostmasters that there was a thief in 9 the branch or someone misusing Post Office funds? 10 A. Yes, I think I still had an open mind. I think I put 11 that as an example of being that case. I think, if any 12 postmaster had come to me -- and I guess the 13 relationship with an area manager was different from 14 contracts manager because you are visiting the branches 15 and you get to know these people because, at the end of 16 the day, you know, they are human beings. They were 17 happy, they were comfortable taking you into their 18 confidence and say "Look, this has been going on for 19 a while, Brian, this is what I'm doing. Is there any 20 more that I can do to prevent or reduce these 21 shortfalls?" 22 That's where I would, you know, possibly look at 23 extra training, if it was available, or, with my 24 experience of coming through the branch network, say 25 "Well, have you done this, have you checked that? Are 19 1 you being visible", that sort of thing. 2 So I wouldn't immediately default to saying that 3 it was that, because of that example. I gave you that 4 example because I remember it. 5 Q. If we could turn up POL00033169, please. These are 6 a series of slides that you've seen about the role of 7 the contract manager. You say you don't know where 8 these slides are from or the audience but that the 9 content looked accurate; is that right? 10 A. Yes. Yes, my immediate observation was there's no date 11 or time on it. What I would expect to see in 12 a presentation of this type would be an author. So 13 typically on slide 1, there would be an author or the 14 presenter would be on there. But when I looked at it 15 a bit closer, I do see that in the notes it mentions -- 16 it uses the terminology "instructor". 17 So what I've deducted for that is that, at some 18 point, possibly following a restructure, the contracts 19 team or somebody in the contracts team has provided the 20 training team with a slide pack to brief new agents of 21 the Post Office as they are working their way through 22 classroom training. 23 Q. If we could turn to page 3 of that slide show, this sets 24 out the network contracts team and we can see you there 25 under contracts advisers. Does this help you at all as 20 1 to when this slide show would have been from? 2 A. What I can tell you is it's post 2006 because this 3 structure -- thinking back at my career and the changes, 4 this structure would have been -- I can't tell you -- 5 I can't give the exact date of this slide deck, 6 obviously, but this structure, these individuals and the 7 line management structure and the support structure 8 suggest to me it's post 2006, but it could be possibly 9 later than that. I'm not sure. 10 Q. We can see there that you answer to a Mr John Breeden. 11 Would that have been correct? 12 A. That's correct, yes. 13 Q. He had line management over all the contract advisers 14 who were split by geographical area; is that right? 15 A. That's correct. He had line management responsibility 16 for all the contract managers in the north, as is says 17 on the slide. 18 Q. If we could turn over to page 5, please -- sorry, 19 actually, if we could go back to page 4, it sets that 20 main roles and responsibilities: 21 "Subpostmaster Recruitment Interviews ... 22 "Conduct/Disciplinary cases 23 "Culpability cases 24 "Debt Recovery 25 "All other contractual issues involving 21 1 subpostmasters." 2 Is that broadly how you understood the role? 3 A. Broadly speaking, yes, that's how the role evolved and 4 that's how it was set, yes. 5 Q. If we could turn over to page 5, please, this sets out 6 "Conduct/Disciplinary Cases". It gives a target. It 7 says: 8 "Target -- 80% of conduct cases to be completed 9 within 6 weeks from date of suspension the remaining 20% 10 to be completed within 8 weeks. 11 "Robust and established process to be followed in 12 all cases ..." 13 Could you explain to us what that target meant in 14 practice? 15 A. Yes, it was very challenging, I'll be honest. It was 16 challenging. I always felt that because you had 17 complexity in the mix. You also had volume, so if you 18 had a lot of cases that formed part of that target. 19 I always prided myself and liked to make sure that any 20 recommendations I was making or any investigations that 21 were being done, six to eight weeks was a very, very 22 challenging target but we had very little control over 23 the setting of these targets that were set basically 24 and, as a team of individuals, we had to do our best to 25 try and work within them. 22 1 Q. Were you put under a lot of pressure to meet that 2 target? 3 A. Yes, I think -- I'm happy to say that, yes. There was 4 a lot of pressure because there would have been the 5 number, the volume, and then usually cases that ended up 6 going down the conduct route would be more complex. 7 They could be unexplained losses. 8 So if you have an unexplained loss, then, in my 9 mind, because I'm not qualified as a data analyst, 10 I would need to seek and look to other areas to try and 11 get some explanation. So six to eight weeks was a very 12 challenging target. 13 Q. Do you think it may have created a temptation to just 14 try and shut down these cases as quickly as possible? 15 A. Not in my mind, no. I would have been quite happy to 16 fail the target but get to the correct answer. I mean, 17 the target was there. There could have been 18 consequences for failing the target, for me as 19 an individual but, in my mind, it was important for me 20 to make sure that when we did provide answers or indeed 21 when we did make a formal decision, we had, you know, 22 investigated every possible area. 23 Q. What about for other people doing your job? Do you 24 think this might have created an incentive for them to 25 quickly want to shut down cases or resolve them? 23 1 A. That wasn't the impression I was getting. The 2 impression I was getting was "Right, we've got to make 3 sure -- well, we've got a responsibility to make sure 4 that the investigations are done properly". That wasn't 5 the impression I was getting. 6 Q. If we could turn over the page to page 6, please, this 7 deals with audits. It says: 8 "Conduct cases -- How can you help? 9 "... Information which would be useful to the 10 Contract Team. 11 "Cash declarations + Last 3 Branch Trading 12 Statements. 13 "Any personal cheques in the account?" 14 Why are personal cheque's in the account 15 potentially relevant? 16 A. Well, personal cheques under the subpostmaster's 17 contract are not allowable. You can't encash personal 18 cheques. You can buy goods and services and use 19 a personal cheque but you couldn't write a personal 20 cheque, for example, and withdraw the money from the 21 branch and use that money to go and pay a bill or 22 whatever. You could pay a bill in the branch by writing 23 a cheque but you couldn't write a personal cheque and 24 then replace that with cash. 25 Q. What does it mean when it says "Horizon event logs -- to 24 1 identify [subpostmasters'] personal involvement"? 2 A. Could I just say, Ms Kennedy, when I've relooked at this 3 again, what I do think is, when I go back to what you 4 asked me at the start, I do believe that this 5 presentation may have been presented to audit members 6 who work in the field. You know, we're looking at this 7 slide here and it talks about information that would be 8 made available to the contracts team on the day of the 9 audit. It seems to make more sense now that this would 10 have been a presentation from the team leader on the 11 audit team to members of the audit team. 12 Q. In order to help them assist you as contract managers? 13 A. Yes. So when they do -- I mean, the whole point of this 14 was that, when you eventually had the conversation with 15 the postmaster or your line manager at the end of the 16 audit, instead of saying to the postmaster "Look, we're 17 going to have to go away and check this stuff or find 18 out what's actually happened with regard to these 19 areas", it was really just to make sure that they were 20 taking responsibility for checking these things when the 21 conversation took place. 22 Q. Turning back then to Horizon event logs? What were 23 those and how did they identify subpostmasters' personal 24 involvement? 25 A. From memory, I would have been heavily dependent and 25 1 guided on what the auditor was telling me, you know. So 2 if there had been an event or something that had taken 3 place in that event that looked peculiar or abnormal, 4 I'd be heavily reliant on him to say "Look, Brian, well, 5 this was done but it doesn't look quite right". 6 Now, if that had been a systemic problem, if they 7 said to me, then we would have had to have that 8 discussion but they may have been able -- at that point 9 in time, before any further investigations took place, 10 I might have been happy to accept their explanation 11 before I had a discussion with my line manager. 12 Q. So, generally, would you defer to what the auditors 13 thought about these Horizon event logs? 14 A. They had much more experience -- I think I said earlier 15 in my statement, I think, four hours training on the 16 Horizon System and, you know, on an ad hoc basis working 17 on the counter -- they were much better placed through 18 their experience to actually go into -- I think they 19 could go back a month. So any events that had happened 20 in the last, you know, 30 days or whatever -- because 21 I would ask that question if it had been raised, "What 22 have you actually checked here?" I had to be satisfied 23 in my mind that, based on this checklist of reports and 24 other checks that, before I had a discussion with my 25 line manager, every possible check had been done. 26 1 Q. I'm now going to ask you some questions about Callendar 2 Square -- 3 SIR WYN WILLIAMS: Before you do, it's a small point, 4 Mr Trotter, but on the first slide -- we don't need to 5 get it up again -- there was a demarcation between north 6 and south. 7 A. Yes. 8 SIR WYN WILLIAMS: I was curious where north ended and south 9 began. 10 A. To be honest, I think it was a moving line because as 11 you went through the passage of time and the numbers 12 reduced ... in those days it would probably have been 13 running along the Scottish border into north England. 14 SIR WYN WILLIAMS: That's what I wanted to ask you, really. 15 Did the north include parts of the north of England from 16 time to time? 17 A. It did, depending on the structure, yes, at that time. 18 SIR WYN WILLIAMS: Fine. So it wasn't exclusive to Scotland 19 it was sometimes the north of England as well. Fine, 20 thank you very much. 21 A. I think I said as well, at some point in time, through 22 memory, it did include Northern Ireland as well. 23 SIR WYN WILLIAMS: Yes, sure. Thank you. 24 Sorry, Ms Kennedy. 25 MS KENNEDY: Not at all. 27 1 Turning then to Callendar Square, FUJ00083815. 2 This is an "Area Intervention Manager Visit Log", and we 3 can see the name there is Sandra MacKay, who was the 4 area intervention manager; is that right? 5 A. That's correct, yes. 6 Q. We can see that the branch there is Callendar Square and 7 this is 12 January 2006. If we could scroll over to the 8 second page, please, and scrolling down -- actually 9 sorry, up again -- it says under "Action": 10 "Brian to email Shaun Turner to request that 11 Horizon kit is checked/replaced to try to eliminate 12 problems currently being experienced in the office." 13 Scrolling down, it says: 14 "As instructed by APM, I visited the branch to go 15 over the Audit Report of 8 December 2005. Brian 16 Trotter, C&SM was with me during the visit." 17 So you have gone along with Sandra MacKay to this 18 visit following an audit; is that right? 19 A. Yes. The reason behind that was Sandra was new to the 20 job. It was a new role for her, although I had known 21 her previously in some other roles. 22 The other reason was that I knew the branch well 23 from my area manager days. From a location point of 24 view it's less than 5 miles away from where I live. The 25 postmaster I knew pretty well, as well, again from 28 1 previous structures, and he also had another branch 2 nearby. So the postmaster in question here, although 3 this is about Callendar Square, he did have two 4 branches. 5 So a combination of those things, I felt that it 6 was appropriate to go along. In addition to that, 7 Sandra and I had obviously had some telephone 8 conversations about or worries about Callendar Square 9 and what the postmaster had told her. 10 Q. So you wouldn't normally go along to this or necessarily 11 go along to this type of visit? 12 A. No, no. 13 Q. I think you say in your statement that you think that 14 this was brought to your attention via -- or this visit 15 came about because of the helpline; is that right? 16 A. Yes. I'm just trying to place it in a time. 2006. The 17 NBSC would probably have been in operation then. The 18 postmaster, again looking at the emails, it looks like 19 he's already escalated it to the Horizon System Helpline 20 and also, I believe, the NBSC. So that escalation has 21 taken place. 22 From what I've deducted, and I'm sort of 23 speculating here, looking at the emails, he hasn't been 24 given or he hasn't received the response that he was 25 expecting, so he's gone back to the helpline and said 29 1 "Well, I'd like to speak to my contracts manager", or 2 whatever. That's come through to the area performance 3 manager or the area office and they've put a high 4 priority on it and asked Sandra to go and visit the 5 office and I've agreed to support that. 6 Q. Returning to the text, it says: 7 "Discussed the report fully with the SPMR and the 8 recommendations that had been made by the audit team. 9 The SPMR is aware of his responsibilities and agreed to 10 complete the training records as outlined in Appendix A 11 relating to AML & FS." 12 What do those mean in that context? 13 A. Sorry, could you repeat the question? 14 Q. What do "AML & FS" stand for? 15 A. Sorry. Anti-money laundering, sorry. That's -- again, 16 these are regulatory requirements by the postmasters, so 17 it's like tests they have to complete, including the 18 staff, and also financial service regulations as well. 19 Q. "All issues in Appendix B were discussed and I am 20 satisfied the SPMR has taken the necessary steps to 21 rectify. 22 "We discussed the problems that had been 23 encountered in September with the Horizon System and the 24 more recent recurrence. Alan (SPMR) showed Brian and 25 myself the balance snapshots from [5 January 2006], 30 1 showing the problems with the communication between 2 nodes. I have already contacted Shaun Turner asking for 3 help to rectify the system problems, and Brian has 4 agreed that he will also email him reiterating the need 5 for the system to be checked or the kit replaced." 6 At this stage, it looks as though or it reads to 7 me as though you think the issue might be with the kit 8 itself rather than Horizon; is that fair? Was that your 9 first instinct? 10 A. That was the impression I got and it was through 11 conversations, obviously, in the office with the 12 postmaster. I also took into consideration that I was 13 speaking to somebody who was very experienced. He was 14 running two branches, running them well, he employed 15 a lot of staff. 16 So I was really taking all those things into 17 consideration when I was sort of coming up with some 18 sort of rationale and, for me, having said that, and 19 although it's not mentioned there, there was also quite 20 a high shortfall, a very high shortfall actually, that 21 had been discussed. 22 So taking all those things into consideration, in 23 my mind, yes, to answer your question, I thought it was 24 the kit, but definitely needed further investigation. 25 Q. You thought it was the kit because you thought, as 31 1 you've just said, this is a good subpostmaster, it's 2 a high shortfall, all of the evidence points to the fact 3 that there might be something else going on but all you 4 could think of at that time was it's the kit; is that 5 right? 6 A. The reason I've said that is because it mentions nodes 7 and I was technical enough to know that nodes was 8 actually a piece of kit that sat in every counter 9 position. So the explanation I was getting or being 10 given was that there seemed to be a problem with the kit 11 communicating with each other but, again, the limited 12 knowledge that I had of the Horizon System, that's sort 13 of where it finished -- it started, sorry, and ended. 14 Q. At this stage, would you have been aware of the prospect 15 of bugs, errors, defects? 16 A. No. No, like I said, going back to what I said earlier, 17 I'd always thought it was fit for purpose and operated 18 as intended. 19 Q. If we could pull up the next document which is 20 FUJ00083770, please, and if we could turn to page 6, 21 this is an email chain from around the same time -- 22 I think it's the day before that log -- and we can see 23 an email from Sandra MacKay to Shaun Turner copying you 24 in. It says: 25 "You may recall that in September the above office 32 1 had major problems with their Horizon System relating to 2 transfers between stock units." 3 So that acknowledges that this is a problem 4 branch, that the NBSC and you were aware there was 5 a problem with; is that right? 6 A. That's correct, yes. 7 Q. It goes on to say: 8 "The SPMR has reported that he is again 9 experiencing problems with transfers, ([5 January 2006]) 10 which resulted in a loss of around [£43,000] ..." 11 That's the large shortfall that you were referring 12 to a moment ago; is that right? 13 A. That's correct, yes. 14 Q. "... which has subsequently rectified itself. I know 15 that the SPMR has reported this to Horizon Support, who 16 have come back to him stating that they cannot find any 17 problem. 18 "Clearly the SPMR is concerned as we have just 19 spent a number of months trying to sort out the first 20 instance and he doesn't want a repeat performance. He 21 is convinced that there is something wrong with his 22 Horizon kit. I would be grateful if you could 23 investigate this and give him any support that you can. 24 I'm due to visit the office tomorrow to have a look at 25 his paperwork and discuss the situation with him." 33 1 If we scroll up, it's an email from you then to 2 Sean, saying: 3 "Further to Sandra's email, I visited the branch 4 with Sandra last week and the SPMR provided clear 5 documented evidence that something very wrong is 6 occurring with some of the processors when carrying out 7 the transfers between stock units. To be absolutely 8 sure from our side can we either carry out a thorough 9 check of the alleged faulty processors or swap them 10 out." 11 So at this stage, you are very much convinced that 12 the problem is not the subpostmaster, the problem is the 13 system itself; is that fair? 14 A. Yes, so basically during the visit the postmaster had 15 presented to us a number of documents, I think they were 16 transfer receipts, showing that although it was going 17 through one node it wasn't appearing at the other. So 18 with our -- because I would class Sandra in this as 19 well -- with our limited knowledge of the kit, how it 20 operated and also the software, I personally felt 21 responsible for making sure that we could take this as 22 far as we could take it. 23 My mind at this time, if you're asking the 24 question, was on the kit and also the shortfall, in 25 getting things sorted out so we could get things back to 34 1 a steady state and the postmaster would feel and his 2 staff would feel confident in using and operating the 3 system. 4 Q. If we could turn up your statement again, please, it's 5 WITN00980100, please, and if we could turn to page 10 6 please, paragraph 33, it says: 7 "This appeared to be an isolated issue and it was 8 not within my skills or remit to understand the nature 9 of these problems." 10 Is that right? Was it really an isolated issue 11 because it seems, on the basis of what we've gone 12 through, that this was something that had happened in 13 the branch before and was continuing to happen? 14 A. From my experience and knowledge, it was isolated to 15 Callendar Square. I think that's what I'm saying there 16 in my statement. When it did reappear or reoccur, I had 17 no doubt in my mind that it needed and required further 18 investigation. 19 But in terms of what I put in my statement here, 20 although it says "isolated", I do accept that it did 21 happen again. 22 Q. If we could turn up the next document, POL00030241, 23 please, this is another email chain with some overlap to 24 the last one but, if we look at this front page, we can 25 see that Shaun Turner -- and scrolling down, please -- 35 1 is emailing you and Sandra to say: 2 "Pretty much the same status with Callendar 3 Square." 4 So we're now in March, this is 2 March: 5 "They need to let Horizon Systems Desk know if 6 they have further problems, and the fix should be down 7 to them with the S90 release as stated in my previous 8 email. As you can see from the email below though, 9 there is now recognition that is [wider] than just 10 a software 'quirk' at just one branch, which means it is 11 now being actively managed as a cross domain problem 12 with Fujitsu." 13 So Shaun Turner is telling you in terms there, 14 this isn't isolated, this is an issue that is affecting 15 numerous branches. 16 A. Yes, I accept that's how the email reads, yes, I accept 17 that. 18 Q. Do you remember receiving this email? 19 A. Not specifically. Obviously, it's happened quite 20 a considerable period of time ago. So, without seeing 21 the bundles, I don't specifically remember seeing that 22 email and reading it at the time. 23 Q. But isn't that quite shocking? You thought that there 24 was nothing wrong with Horizon and here you are being 25 told that there's an issue that's cropping up in 36 1 a number of places. 2 A. Well, it was shocking to me because, if we put the email 3 in its time and place, the conversations or discussions 4 that I would be having with my colleagues in the team 5 and also with my line manager, for me, I don't recall 6 being told or somebody saying to me "Look, this is 7 a bigger problem that we need to worry about". For me, 8 that would certainly -- there'd be alarming bells 9 ringing for me. 10 Yes, I do accept what you're saying there. 11 Q. If we turn to page 3 -- so this is a thread I think 12 that's been forwarded to you. So you would have 13 received the rest of the email thread and, if we scroll 14 down, we can see an email from Anne Chambers. Did you 15 ever come across Anne Chambers? 16 A. No. One of the things I've deducted from the bundles 17 and email chains, in quite a number of the emails myself 18 and Sandra MacKay were not copied in. So, again, going 19 back to what I knew of these emails, what investigations 20 were going on was completely unknown to me. 21 Q. But I mean, if we scroll back to the first page and to 22 the bottom, it looks as though this particular chain has 23 been forwarded to you. I appreciate you weren't copied 24 in to the email I was about to take you to but you were 25 forwarded this email chain, were you not? 37 1 A. Yes, yes. 2 Q. So -- sorry -- you go. 3 A. I don't recall seeing it, if that's the question that 4 you're asking me. My main focus, I guess, was on the 5 latest email, what was being reported, what 6 investigations had been done, and I think I did say in 7 my witness statement that, when I reviewed these emails, 8 some of the terminology that was being used was way 9 outside of what I understood of, you know, how the 10 software operated, how the hardware worked. 11 I struggled with some of the terminology and 12 I think I've said that in my witness statement. 13 Q. If we could turn back to page 3 and if we could scroll 14 down, it may be that this is one of those emails where 15 you say that you don't understand the terminology but 16 I'm going to take you to it. 17 So if we look at this email from Anne Chambers, it 18 says: 19 "Haven't looked at the recent evidence, but I know 20 in the past this site had hit this Riposte lock problem 21 2 or 3 times within a few weeks. This problem has been 22 around for years and affects a number of sites most 23 weeks, and finally Escher say they have done something 24 about it. I am interested in whether they really have 25 fixed it which is why I left the call open -- to remind 38 1 to check over the whole estate once S90 is live -- call 2 me cynical but I do not just accept a 3rd party's word 3 that they have fixed something! 4 "What I never got to the bottom of, having usually 5 had more pressing things to do, was why this outlet was 6 particularly prone to the problem. Possibly because 7 they follow some particular procedure/sequence which 8 makes is more likely to happen? This could still be 9 worth investigating, especially if they have continuing 10 problems, but I don't think it is worthwhile until we 11 know the S90 position." 12 So this email, is this an email that you would 13 have looked at and thought "I don't understand the 14 terminology there or the technological speak, I'm not 15 going to engage in it"? 16 A. I case if I put it in context, there's two things. The 17 technological speak, I would have struggled with. 18 I guess in hindsight, the alarming thing for me, having 19 seen it in the bundle, is that it had been going on for 20 years. Going back to what I said earlier in my witness 21 statement, that the people I was speaking to, the 22 comments that I was getting, was the bigger picture, you 23 know the wider picture was this appeared to be isolated. 24 So putting this in context in this email chain, 25 that would alarm me, having seen that that there's 39 1 a wider problem. I guess at the time if I'd seen it 2 I would have been speaking to my boss and my line 3 manager and saying, "Well, is there a wider problem" and 4 he may have said to me -- well, he may have known or not 5 known but, if there had been a wider problem in my area 6 with more branches having the same sort of issues, 7 I would like to have known about it. 8 Q. I mean, she also seems to say that she's not convinced 9 that this fix will actually work. So there's a big 10 problem but there's also a technical person saying "I'm 11 not sure this fix will actually work". Isn't that 12 extremely concerning? 13 A. It is yes, it is. I accept that. 14 Q. So as I've taken you to, this was an email that you were 15 forwarded at the time. What would it have taken for you 16 to go to your line manager and say "This is a real 17 issue, I'm worried about the system"? Would it have 18 been someone saying to you there's a problem with the 19 system we need to take action? What would it have 20 taken? 21 A. It would probably be somebody more qualified than me to 22 say, "Look, actually, reading this email in its context 23 there's a bigger issue here, it needs escalated" and 24 I would then speak to my line manager and say, "Look, 25 you know, it's not just Callendar Square, according to 40 1 this individual's email". 2 I wouldn't have been frightened to push it back up 3 the line, if there was a wider problem, if that's what 4 you're asking. I wouldn't have just sat on it and 5 thought "it's only Callendar Square and that's it". But 6 I could only comment on what I was hearing at the time 7 and being told at the time. 8 Q. If we could turn up your witness statement again 9 WITN00980100 and page 21, please. Just looking at 10 paragraph 78 there, which is at the bottom, you say: 11 "The limits of my role in investigating incidents 12 meant that I was reliant on the audit team, the security 13 team, and any associated teams eg IT teams or Horizon 14 teams into would have been involved if there were 15 allegations or suspicions of system errors. With the 16 exception of the incident above", which is the Callendar 17 Square one; is that right? 18 A. That's correct, yes. 19 Q. "... where Fujitsu were involved, I was not aware of any 20 credible suspicions of system errors. In the cases we 21 investigated, the issues were resolved by training, if 22 there was a suspension by appointing 23 a temporary/replacement postmasters or explained by 24 admissions from postmasters. As a result, there was 25 a context which pointed towards human error being the 41 1 cause of issues and not system errors. It would have 2 been impossible for someone in my position to 3 discriminate between human errors and system errors but 4 I accept that the same might be true of postmasters 5 themselves in some cases." 6 With the benefit of hindsight, wasn't this 7 Callendar Square incident -- couldn't it have been 8 a huge wake-up call for you to look at whether or not 9 there were system errors when shortfalls arose for 10 subpostmasters? 11 A. It could have been, yes, but, like I say, I was doing my 12 best in the role that I was in, to push as hard as 13 I could back to the technical teams, people that were 14 much more qualified than me to look at why, you know, 15 the tech wasn't communicating with each other. 16 The other issue was this 43k shortfall that 17 appears to have been resolved. I haven't seen any 18 mention of that in the bundles but I think I was trying 19 to do the best that I could do with the information that 20 I had in speaking to people within my sphere, that could 21 push it harder. 22 Q. If we could take that down, please. 23 I'm now going to move to ask you some questions 24 about another incident. If we could turn up 25 POL00004403, please. This concerns Winlaton Mill. Am 42 1 I saying that correctly? 2 A. It is, yes, and I believe it's north England, that 3 branch. Going back to what I was asked earlier, I'm 4 kind of confused why I've been involved in this but it 5 may be for some valid reason. Yes. So to answer your 6 question, it's Winlaton Mill. 7 Q. So if we could turn to page 6, please and scrolling 8 down, who is Jacqueline Whitham? 9 A. Jackie Whitham, at that time, looking at dates of the 10 email, would have been quite senior, I think, maybe in 11 the Product and Branch Accounting team. She would have 12 been responsible for flagging or pushing this paperwork 13 out to the contracts team for -- well, basically to 14 escalate it and contract intervention. 15 Q. Is that what she's doing here by emailing you? 16 A. Reading the email and again trying to rely on my 17 knowledge and experience, the form that's being referred 18 to at the time was as process that had been agreed, 19 probably at quite a higher senior level, on how we 20 should deal with any shortfalls or any discrepancies 21 that had occurred in branches. 22 Q. If we turn back to page 5, we can see that there's an 23 outstanding debt. That's why this has come to you. If 24 we scroll down we can see that you then email Nick 25 Barnard -- sorry, Neil Barnard. Who was Neil Barnard? 43 1 A. So, again, probably another restructuring, I'm not sure 2 of the time. Neil was a business development manager. 3 So he was responsible, a bit like when I was an area 4 manager, for developing the relationship between him and 5 the branches in his area. 6 Q. What you are doing in this email, which is in 7 November 2006, is you say: 8 "Please see the attached. I think this warrants 9 further investigation. Can you contact the branch 10 advise that because a debt is already be repaid this new 11 debt will need to be settled in full immediately. If 12 the branch is not in a position to repay I may have to 13 consider their contractual position." 14 What you mean by "consider their contractual 15 position"? 16 A. Basically, that statement ties in or is aligned to that 17 process. So if the paperwork had been referred to the 18 contracts team -- again, I'm working on my memory -- 19 there would have been a target to get it back to say, 20 "Look, actually, we've already done some investigation 21 centrally, that's been done, evidence has been produced, 22 that's been done", so it would have now been passed to 23 me to see if possibly there was any grounds for 24 recommending write off. 25 I see from the paperwork this postmaster's fairly 44 1 new. I'd be thing about how much training he got, how 2 he was coping and that's where Neil would have come into 3 the equation because of his relationship with the branch 4 and the postmaster. 5 Q. So Neil was going to investigate whether or not there 6 was any basis upon which the debt could be written off. 7 A. Yes, it's like I said earlier in the conversation, Neil 8 was better positioned and placed, because he already had 9 that relationship with this postmaster, to sit down in 10 the branch and just go through it step by step to try 11 and get his side of the story or version of events 12 before we jumped to any sort of "Right, okay, you've got 13 to pay it back and that's it". 14 It was very much a case of let's find out exactly 15 what's happened here. 16 Q. That last line, which says, "If the branch is not in 17 a position to repay I may have to consider their 18 contractual position", that suggests that, if the branch 19 can't repay, they may be terminated; is that fair? 20 A. That doesn't suggest that. Contractual position might 21 mean, like, you know, sending a letter to the postmaster 22 and saying "Look, we've been enable to get 23 an explanation for this. Under" -- at that time, again 24 looking at the date -- "under 12.12 of the contract 25 you've got a liability for all losses. You know, you've 45 1 had the conversation with Neil, would you like to come 2 and speak to me?" 3 It wouldn't be an immediate default to terminating 4 somebody's contract because we couldn't get some answers 5 as to why a shortfall or a debt had occurred in the 6 branch. 7 Q. If we could turn back up the chain to page 4, please, 8 and scrolling down, we can see what Neil says after that 9 meeting. He says: 10 "I've made a tentative arrangement with the son of 11 the subpostmaster (currently off sick) to drop in at the 12 branch on Wednesday afternoon, however, I thought 13 I would come back to you to clarify some concerns I have 14 about this. 15 "During the conversation with the son of the 16 subpostmaster, it appears that they have no argument 17 against the payment of the latest shortages, however, 18 the earlier discrepancy of £4,000 is the one they 19 dispute. It appears that the branch was informed of 20 a remittance that hadn't been accounted for, and being 21 new to the Post Office were talked through how to 22 process through Horizon without scanning the advice 23 notice. The result was a discrepancy in the following 24 balance. 25 "I was told that the branch has not signed any 46 1 agreement for deduction from remuneration for repayment, 2 which certainly used to be a requirement in the days 3 I last got involved with this sort of thing. The branch 4 would like the opportunity to search for the paperwork 5 relating to the cash delivery and get some help in 6 investigating what has gone wrong. At this stage I'm 7 not sure who would help them, as I would certainly 8 struggle." 9 Can you explain to us what's going on here? What 10 is he describing that's happening? 11 A. Well, I think there's couple of things here. I think he 12 mentions the fact that, you know, if a repayment plan 13 has been agreed with a postmaster, it needs to be 14 agreed. We can't just automatically default to 15 enforcement. He's also going on about the 4,000 dispute 16 about, and I think that's down to some remittances into 17 the branch. 18 For me when I looked at this paperwork in the 19 bundle, I'm at a loss to see what I actually did. You 20 know, Neil's obviously sent me this back me. Me reading 21 this fresh, it being sent to me, the questions I would 22 be saying in my mind is "Okay, we've got this issue 23 about the receipts, this other thing", I think it's in 24 the second paragraph about the £4,000 discrepancy, and 25 also what decision I made. There's nothing in the 47 1 bundle that actually shows clearly what actions I took 2 following this email. 3 If there is, I apologise for missing it but 4 I can't see it. 5 Q. Let's just take it step by step. So at the moment, I'm 6 just asking you about this email and I'm about to ask 7 you then about the next email that Neil sends, which is, 8 if we scroll over to page 3 and scrolling down, this is 9 an email that says: 10 "With reference my recent visit to the above 11 branch to discuss the various discrepancies at the above 12 branch. There were a number of points raised which 13 I hope you can help with some clarification/advice." 14 He raises a number of questions there asking for 15 further guidance. He then says at the bottom of that: 16 "If you can provide the dated [scrolling over] and 17 evidence to support this error it may be possible to 18 shed some light on how such a small branch could 'lose' 19 an amount equivalent to the remittance. 20 "Although I have no previous knowledge of the 21 branch, it would appear that the branch has been naive 22 in accepting all the above without question and without 23 any supporting evidence. As things stand, they will end 24 up paying half of their remuneration back to cover these 25 repayments, which would certainly affect the viability 48 1 of the branch." 2 So leaving aside any decision that you did or did 3 not take on this branch, generally was the attitude: it 4 doesn't matter whether it looks ridiculous or 5 implausible that a branch could lose this money, they're 6 still liable if there's a debt showing on Horizon or 7 generally? 8 A. Generally, that's what the contract said but I think, 9 going back to the top of that email and who it had been 10 addressed to, it looks like conversations have already 11 taken place directly with the postmaster that didn't 12 involve the contract team for enforcement. 13 That's what I go back to. I guess the last 14 paragraph there. There has been naiveté and I don't 15 really remember if the postmaster or somebody else 16 contacted me directly to see, "Look, this is ridiculous, 17 you know, we're having to pay this money back", and 18 these investigations haven't been done. 19 But when I go back to the top of the email, 20 I guess to answer your question, I trusted these 21 individuals that had been dealing with this type of 22 scenario and situation daily, that they would take 23 responsibility for investigating any of these errors, 24 shortages in the branch fully before it came to the 25 contracts team. 49 1 Q. If we could then turn to page 2 on this email thread -- 2 so this is further up again -- this is your email then 3 which says "Neil", and this is following the emails that 4 we've just gone through: 5 "As far as I can see to date we have not received 6 any documentary evidence from the subpostmaster stating 7 that he is not liable for the loss of £1,463.07. 8 I therefore have two options. 1, you have one last go 9 at recovering the money or 2, I write to the 10 subpostmaster and invite him to a fact finding interview 11 to explain why he is still refusing to repay. If you 12 opt for 1, can you let me know how things progress." 13 So here you are saying if we don't have any 14 documentary evidence from the subpostmaster themselves, 15 we're potentially going to enforce the debt obligation; 16 is that right? 17 A. I think what I'm saying in that email is that if it's 2 18 in its contracts, I would like to speak to the 19 subpostmaster directly because he may have something to 20 say to me or show something to me that might involve me 21 pushing it back up the line again. 22 I think I said at the start I wouldn't 23 automatically default to, "Right, you're paying the 24 money and that's it". I think it's important that we 25 get a full explanation from the postmaster, and 50 1 I realise and appreciate there's other emails in the 2 bundle and in the email chain where conversations have 3 taken place. 4 In terms of the process for this, I would be under 5 scrutiny, yes, to provide answers because, like any 6 other debt recovery process that was in place, there was 7 targets, there was timescales. So I guess the question 8 would be getting asked of me, "What have you done to 9 progress this?" and rather than just say, "Right, that's 10 it, you have to pay the money back because that's what 11 your contract says", in my mind I still wanted to be 12 satisfied that I had a conversation with the postmaster 13 to possibly just go through it again, review the 14 paperwork. I might have recommended actually he's new; 15 I'd look at the training; does this warrant write off, 16 and I'd push it back up the line. 17 So that's when I said to you, yes, it's important 18 in its context here but my observations in reading the 19 emails, there's no final decision from me here from what 20 I did, what I said, who I passed it back to. 21 Q. Did you feel like you were ever under pressure from the 22 Post Office to recover debt and to gather money for the 23 Post Office? 24 A. Yes, I'm happy to say that, yes. There was targets. 25 They were performance-related; so yes. Using this as 51 1 an example, there was a target for this process. 2 Q. What was that target? 3 A. I can't remember but it may have been a couple of weeks. 4 You know, typically how it would work is all of the -- 5 well, just to take it back a step. The discrepancy 6 would come to light, conversations would take place 7 (probably lengthy ones) with the postmaster and the 8 product branch training team. When they had been 9 exhausted, then typically it became part of the 10 concurrence process. 11 From memory, I believe that I had a target, 12 a deadline, to push it back up the line and say, "Look, 13 this is what's actually been done". So, yes, to answer 14 your question, there was pressure, yes. 15 MS KENNEDY: Chair, that might be a convenient moment for 16 a break. I don't have much left at all. Would now be 17 a fine moment for a break? 18 SIR WYN WILLIAMS: Yes, of course. So what's the time now? 19 MS KENNEDY: 11.10. 20 SIR WYN WILLIAMS: All right. 11.25. 21 MS KENNEDY: Yes, thank you, Chair. 22 SIR WYN WILLIAMS: Thank you. 23 (11.11 am) 24 (A short break) 25 (11.26 am) 52 1 MS KENNEDY: Picking up from after the break, Mr Trotter, in 2 2009 were you aware of a Computer Weekly article. 3 A. I was aware of it, yes. I'd heard it being spoken about 4 within the business. From memory, I may have read it, 5 yes. I do remember hearing about it, yes. 6 Q. What were people saying about it within the business? 7 A. I think the general feeling was that this article had 8 been written -- if you are asking me about the 9 credibility of the article, I don't think I would be 10 qualified to actually say to you what my understanding 11 was of what was being said against the messaging in the 12 business. 13 So although I may have read it, I don't think I'd 14 have been qualified to put that alongside what I was 15 being told in the business, in terms of the Horizon 16 System and its operation. 17 Q. What were you being told in the business at that time? 18 A. As I said in my statement, I can only speak from my user 19 point of view, albeit limited, and it all seemed to work 20 okay when I used it, and through my involvement and 21 interactions with agents, they seemed to be limited. 22 When there was a question mark, with the limited power 23 that I had I tried to push it as far as I could push it 24 and put it in the hands of what I thought were qualified 25 people, and that's as much as I could say about it. 53 1 Q. Do you think there was a sea change in 2009 or a more 2 forceful message being communicated within the Post 3 Office that Horizon was robust and it couldn't be at 4 fault? 5 A. Possibly. I did watch some of the sessions yesterday 6 and it did prompt some reminders to me. Yes, I don't 7 recall actually seeing those communications but it -- 8 certainly it can't be ignored. There's dates there, 9 there's information there about the Horizon System, its 10 integrity and that sort of thing. 11 So having watched the Inquiry and watched the 12 sessions yesterday, at that time, if it's, you know, in 13 that context, it could have been the case. 14 Q. I want to ask you about one more document. If we could 15 pull up POL00005245, I know you say you don't recall 16 this note or this meeting and you don't know who wrote 17 it. I'm not going to ask you in detail about this 18 particular case but we can see that it's a meeting, 19 Monday, 27 July 2015, and someone has written it's 20 a meeting with you as the agent contract adviser -- 21 A. Yes -- 22 Q. Sorry, go ahead. 23 A. No, I was just confirming that's correct, yes. 24 Q. There's just one aspect that's recorded in this note 25 that I wanted to ask you about, so if we could scroll 54 1 down, there's discussion about a discrepancy and 2 a shortage and trying to resolve that shortage. In the 3 second bullet point, I wanted to ask you about the line 4 that says: 5 "I had to accept the correction as it was 6 a Wednesday and with balance etc I couldn't continue 7 without doing so. I spoke to Jill Southern who issued 8 the correction on behalf of the cash centre." 9 Was your understanding of the Horizon System that 10 you had to accept something or you'd be prohibited from 11 continuing to trade? 12 A. I can only speak from my knowledge and experience but my 13 understanding of the issue of transactional corrections 14 were, if they were issued to the branch, then they did 15 have the ability to send them back or speak to somebody 16 and say, "Look, actually, this warrants further 17 investigation". But I'm talking really from an 18 experience. 19 If that had been put in front of me, I would 20 probably have had to go away and check with somebody and 21 say "Look, if you get" -- it's an electronic message, 22 basically, but there is a possibility that -- if it had 23 landed at certain times of the month because at the end 24 of every month there were mandatory procedures but I'm 25 not 100 per cent sure if it had to be -- I think what 55 1 you're asking me is is this forced and I'm not 2 100 per cent sure. 3 Q. What were the mandatory procedures that you just 4 mentioned? 5 A. The mandatory monthly procedures are completing the 6 Branch Trading Statement, where you have to make 7 a declaration at the end of that, obviously, and you've 8 got the option there to settle centrally any 9 discrepancy. Whether that formed part of this and it 10 was settled centrally and it became part of a wider 11 investigation -- I mean, I do recall from memory that 12 there was some cheques -- some problems, sorry, with 13 cheques at this Post Office and that I think, through my 14 intervention, we pushed for further investigation, just 15 to try and bottom out why there was a problem. 16 But to answer your question, technically, I don't 17 think I'm 100 per cent sure if this is a forced 18 instruction that the postmaster would have to have 19 complied with. 20 Q. That document can come down. Thank you. 21 There are a few questions from the Core 22 Participants. One of those questions is: were you aware 23 of members of the audit team being union members? 24 A. I mean, I guess that they could be in the union but 25 would that have been -- 56 1 Q. Was it something you were aware of at the time? 2 A. No. No, their personal circumstances might have been 3 some interest but to answer your question, no. 4 Q. Were you aware if there were ever situations where 5 an auditor was investigating a fellow union member? 6 A. No. 7 Q. You mention in your statement that you would investigate 8 issues if they were raised by an NFSP representative. 9 What would you do if there were issues raised by an NFSP 10 representative? 11 A. Well, I'd like to say I certainly prided myself on 12 having a good relationship with the NFSP. So, 13 typically, outside the sphere of it being through 14 an audit, if they had come to me and said, "Look, Brian, 15 this doesn't look right, can you take it forward", 16 I think throughout my career I encouraged tried to 17 encourage the dialogue and the relationship we had with 18 NFSP. But I would struggle to actually give you 19 an example of an actual case. It was more about the 20 relationship and working together. 21 Q. Did you feel the NFSP stood up for their union members 22 effectively? 23 A. Absolutely. Yes, that's the impression I got, yes. 24 Q. Investigations carried out in Scotland had to be handed 25 over to state agencies to prosecute. Do you know 57 1 whether this had any effect on how investigations were 2 carried out? 3 A. I've got no idea. Like I said -- I think I said in my 4 statement, the interactions that I had personally in my 5 role were limited with the security team. 6 Q. I think you mention in your statement that you received 7 media training. 8 A. Yes. 9 Q. What kind of training is that? 10 A. The whole point of the media training was -- and it was 11 probably -- I went through I did twice, actually. It 12 was more to deal with any comments that we got from the 13 media, the public, about branches closing, so that we 14 were equipped to actually explain why a branch had shut. 15 So, for example, it could have been as a result of 16 a suspension. If any calls were fielded, we felt that, 17 or the business felt, that we should be equipped to deal 18 with those sorts of calls of enquiries. 19 Q. What would you typically be told to say? 20 A. Well, if it was a suspension, it was a confidential 21 matter between the Post Office and the individual, so 22 we'd be told to say -- I mean, there would be a brief. 23 Basically, "unexplained circumstances", you know. It 24 was kept very much as a private matter between the 25 individual and the Post Office, until that investigation 58 1 had been concluded. 2 The conversation really that we wanted to have 3 with the media was the efforts we were making to 4 reinstate service if a closure had taken place. It was 5 more like a positive discussion rather than negative. 6 Q. Were you ever briefed to say it's closed because the 7 subpostmaster was stealing from the till or anything 8 like that? 9 A. Never, never, never in my experience. Never. 10 Q. I understand that you are now back working for the Post 11 Office; is that right? 12 A. That's correct, yes. 13 Q. What are you doing at the Post Office now? 14 A. I actually joined -- rejoined the Post Office last year 15 in July on a fixed-term contract for a year. So I work 16 in the historical matters unit dealing with postmasters' 17 claims and redress. 18 Q. What does that involve? 19 A. Well, it's basically -- the area that I look in is 20 dealing with claims of -- it's classed as lost pay or 21 pay lost during suspension. So it's going back over 22 when the policy changed, I think it was 2011. So any 23 postmasters that lost pay, they can actually apply to 24 the scheme to have that the lost monies repaid. 25 Q. Is that connected with Horizon or something else? 59 1 A. It's connected with suspension, right. It could have 2 been any suspension case, it's not specifically Horizon. 3 ^^. 4 MS KENNEDY: Thank you, Mr Trotter. Those are the end of my 5 questions. 6 I can see Mr Jacobs has a question. 7 Questioned by MR JACOBS 8 MR JACOBS: Thank you. I have couple of questions in 9 relation to a couple of the clients who I represent. 10 Mr Trotter, I act for 156 subpostmasters who 11 instruct Howe+Co and you have been asked about your role 12 in investigating subpostmasters. 13 I want to ask you about one of our clients, Louise 14 Dar. You may recall you gave evidence in the Group 15 Litigation and she was a lead witness there. 16 Can I take you to WITN022890100 (sic), please, and 17 it's page 15 of 20. That should come up on your screen 18 in a minute. Just waiting for it to come up. 19 MS KENNEDY: I'm afraid I am being told the number is wrong. 20 MR JACOBS: I will try it again WITN02890100, it's the 21 witness statement of Louise Dar. Great, thank you. 22 If we could have page 15 of 20 up, please, and go 23 to paragraph 87. Ms Dar says in that paragraph: 24 "I was treated like a criminal by the Post 25 Office~..." 60 1 This is in relation to the alleged shortfalls 2 emanating from the Horizon System and she says when she 3 sought help: 4 "... the Post Office audit team were extremely 5 callous and made no attempt to find the root cause of 6 the alleged shortfalls. Specifically, Brian Trotter my 7 contacts manager, was particularly keen to get me to 8 admit to falsifying the books. He asked me to admit to 9 this several times." 10 Do you recall this? 11 A. Yes, I've watched the Human Impact video twice. I've 12 actually read the statement twice. 13 Q. Oh, good. 14 A. I'm shocked by that comment, quite frankly. I can't 15 prove this discussion didn't take place but it's not the 16 sort of thing that I would have been saying to anybody 17 and I'm not completely sure what audit she's referring 18 to, when it took place, what the shortfall was, but it's 19 not -- I think, in the Human Impact hearing I think she 20 does refer to it as a phone call, several phone calls. 21 Q. Yes, and she said in her evidence in the High Court that 22 this happened within phone calls about seven or eight 23 times between you and her and you would repeatedly ask 24 her "Did you falsify the books, did you falsify the 25 books?" So that is her account. Do you remember 61 1 speaking to her on the phone? 2 A. I may have spoken to her on the phone about several 3 things, obviously, at the start of her journey when she 4 was applying for the Post Office. She had several 5 problems with her application. That was before she took 6 over. So, yes, telephone calls or conversations would 7 have taken place. 8 In terms of my role in making sure that I kept to 9 process, if that's the best description, it wasn't the 10 done thing to actually discuss things of this private 11 nature on a telephone call. If a face-to-face meeting 12 had taken place, generally speaking it had been recorded 13 and the postmaster got a copy of that recording. 14 But I can't remember having these conversations, 15 I'm sorry, if that's what you're asking me. 16 Q. You have said in your evidence that you were under 17 pressure because of timescales and deadlines. Many of 18 our clients have said they were told when interviewed 19 and during audits that if they pleaded to false 20 accounting they would not be prosecuted for theft. 21 Is this something that you were aware of and were 22 you under instructions to obtain a confession from 23 subpostmasters in relation to falsifying accounts? 24 A. Well, that statement would be outside of my sphere of 25 control and responsibility anyway because I wouldn't be 62 1 dealing with prosecutions. I'd be looking at 2 contractual breach and things that had actually happened 3 in the branch. So I wouldn't be looking to agree 4 something with Ms Dar that was outwith my control. Like 5 I say -- 6 Q. I think the question was, really, this wider idea that 7 the Post Office were trying to get subpostmasters to 8 agree that they were guilty of false accounting in 9 relation to dropping a theft charge came at a later 10 point. I just want to know: did that filter down to the 11 initial interviews in the initial investigations? Was 12 that something that contracts managers or investigators 13 were trying to look at during that process, that earlier 14 process? 15 A. Not really, we went through a strict -- it was a strict 16 protocol, actually, of reports that had to be done. Any 17 decision or any recommendation that I made was under 18 heavy scrutiny. I think I mention in my witness 19 statement I didn't make the final decision on any of 20 these and, certainly, every -- you know, the benefit of 21 the doubt would have been given to the agent. If Ms Dar 22 had said something to me, "Brian, I've got these 23 unexplained losses, I'm tearing my hair out, can you 24 help me", it's in my nature to be helpful and 25 supportive. Like I say, I do not recall having these 63 1 conversations or saying anything like that. 2 Q. Were you under instructions -- I mean, you've said 3 earlier on, in respect of your answers to Ms Kennedy, 4 that several subpostmasters made admissions, made 5 confessions. Were you under instructions to obtain 6 admissions or confessions from subpostmasters? 7 A. No, no. Like I said earlier when I was being asked the 8 question -- and I can't put a percentage on it, so I'm 9 sorry -- but there was a number of cases, a number of 10 times, where almost immediately after walking into the 11 office the postmaster would want to speak to the auditor 12 privately to possibly getting it off their chest. 13 But in this particular case, I don't -- well, 14 certainly from memory, that wasn't the situation here 15 from the information I've been sent and my recollection 16 of the case. 17 Q. Well, I have to obviously suggest to you that that is 18 what happened because that's Ms Dar's evidence. 19 A. Well, I can only tell you what I recall and how 20 I conducted myself as a contracts manager. 21 Q. I'm going to ask you about another one of our clients 22 now, Shazia Saddiq. You said that you followed the 23 evidence yesterday. 24 A. Yes. 25 Q. Did you hear the evidence of Ms Peacock? 64 1 A. Yes, I watched some of it, yes. 2 Q. So essentially you would have heard that Ms Saddiq was 3 a subpostmaster with three branches in Newcastle. She 4 paid over £10,000 in relation to Horizon shortfalls that 5 were alleged. Post Office demanded another £20,000 from 6 her, and she became a victim of cyberfraud which she 7 later found out affected 11 other branches, and Post 8 Office sought to recover 33/nearly £34,000 from her. 9 Can we go to her statement, please, and that is 10 WITN02230100. I hope I've given you the right number 11 this time. Thank you. Page 13 of 16, please. 12 If we go to paragraph 72, you will see that 13 Ms Saddiq describes a very distressing experience when 14 she was attacked with the children in the street and 15 called a thief because the Post Office had closed. Then 16 moving on to paragraph 76, this led for her to flee her 17 home. She fled her home with just her children's teddy 18 bears and toys. 19 If we could move please to page 14 of 16, 20 paragraph 82, and if we could probably highlight 82 if 21 that's possible. So Ms Saddiq says: 22 "I have received threatening calls to my mobile 23 phone and emails from Stephen Bradshaw and Brian 24 Trotter. Mr Bradshaw was a post office security officer 25 and Mr Trotter was a post office contracts manager." 65 1 Do you recall contacting Ms Saddiq, Mr Trotter? 2 A. No, no. I'm sorry, I don't. 3 Q. Ms Saddiq says that you telephoned her on at least ten 4 occasions. Do you recall that? 5 A. No. 6 Q. Do you remember any incident when there was 7 a subpostmaster who had a MoneyGram loss and you telling 8 that subpostmaster that they were responsible for paying 9 for that because they hadn't followed procedures? 10 A. What I do recall -- and, I'm sorry, I can't put a time 11 and a date on it -- was when these losses occurred, 12 I do -- and this is from memory, so I apologise. In the 13 contracts team, because of the number and also the 14 values, there was a dedicated team set up -- I wasn't 15 part of that team; I can confirm that -- where they were 16 actually -- they were responsible for engaging directly 17 with these postmasters to talk about these shortfalls 18 that happened in these branches. 19 In terms of -- you know, I may have spoken to them 20 on the phone. I don't believe it was ten times. It 21 certainly wouldn't have been in any sort of threatening 22 sort of way. I may have called her up and said, "Look", 23 actually out of courtesy because that may have been in 24 my area at that time, "this has occurred. Somebody in 25 our team will be making direct contact with you to talk 66 1 about next steps". 2 But I was not -- I do believe and I can -- and 3 I think my memory's pretty clear here. We had 4 a dedicated team within the contracts team at that time 5 who dealt specifically with MoneyGram losses or 6 shortages or shortfalls. 7 Q. Did you -- in your work for recovering losses from 8 subpostmasters, did you deal with the Post Office 9 Security Team? 10 A. Rarely, very rarely. Like I say, they looked at -- if 11 there was any evidence of criminality, they dealt with 12 it. Our role in the contracts team was to deal with any 13 contractual breach. Very rarely did our paths cross. 14 The interactions were few and far between and limited. 15 Q. Ms Saddiq says that you were working with the security 16 officer in her case and that officer was Mr Bradshaw. 17 Do you recall that? 18 A. I don't recall that, no. 19 Q. Can we move through then to paragraph 83 on the 20 statement. Just waiting for it to come on the screen. 21 It's page 14 of 16 so the final paragraph there 22 she says that she received a number of calls that were 23 intimidating from Stephen Bradshaw as security officer. 24 How did the contracts managers and the security team 25 work together? What interaction did they have in cases 67 1 of this kind? 2 A. Like I said, interactions from my experience -- and 3 I can only speak about how I operated -- we should all 4 have been operating the same way -- unless they had some 5 intelligence, some information, to share that was it. 6 But their responsibility was to look at any elements of 7 reported criminality and it was quite clear we were 8 looking at contractual breach that had been as a result 9 of an audit or whatever. 10 In this particular case, if we're talking about 11 the MoneyGram shortfalls, I can't give you an answer on 12 why both parties are involved. All I can tell you is 13 that at this time there was a dedicated team, including 14 a senior manager, who was dealing specifically with 15 a MoneyGram shortfalls and I wasn't in that team. 16 Q. You may not be able to answer this question, Mr Trotter. 17 Many of our clients have said that Post Office security 18 officers engaged in bullying and thuggish behaviour, 19 shouted at subpostmasters, accused them of stealing. 20 Were you aware of heavy-handed behaviour from the 21 security team? 22 A. Directly I wasn't aware of that in terms of -- because 23 obviously, as I've said already, there were independent 24 investigations dealing with -- there could be 25 similarities with different -- but to my knowledge and 68 1 my experience I don't recall ever hearing anything like 2 that, to answer your question. 3 Q. If we could go to the next paragraph, please, 4 paragraph 84. And I accept that you may not be able to 5 answer this question but I want to ask you whether this 6 is something that you were aware of indirectly. So 7 Ms Saddiq says: 8 "On 29 September 2016 at 13:34 Stephen Bradshaw 9 called me and I refused to speak to him because I didn't 10 know who he was or who he worked for. In that telephone 11 call, which was witnessed by my husband on loudspeaker, 12 he called me a 'bitch' which I found extremely 13 distressing." 14 Ms Saddiq says that Mr Bradshaw called her at 15 least 60 times. Were you aware of this sort of approach 16 going on by members of the security team? 17 A. Well, firstly, it's the first time I've seen this 18 statement and I'm shocked by those comments. And to 19 answer your question: no. 20 Q. What procedures were there within the Post Office to 21 curb or to check this sort of thuggish behaviour from 22 the security team? 23 A. I don't know because I didn't work for the security 24 team. Maybe ask me about the contracts team. I think 25 it's been covered earlier in some of the slides about 69 1 the steps, the formal steps, that we were required to go 2 through to make sure that everything was done 3 professionally and appropriately. I cannot comment on 4 what was going on in the security team when I wasn't 5 part of that team. 6 Q. I asked you the questions because it's my client's 7 evidence that you were working closely with Mr Bradshaw 8 on her case. 9 A. I can't -- and the other thing is, without seeing other 10 evidence, I guess -- you know, throughout my career my 11 paths may have crossed at some point with Mr Bradshaw, 12 and indeed other security managers, and the interactions 13 I would say would be very limited. 14 But, like I say, in the -- sorry, in the contract 15 team there was very strict processes and procedures that 16 we were required to follow so that, when a decision was 17 made, we could feel that everything had been done 18 appropriately and properly. 19 MR JACOBS: Well, thank you. I don't have any further 20 questions for you. 21 MS KENNEDY: Chair, I believe there are further questions 22 from Mr Moloney. 23 Questioned by MR MOLONEY 24 MR MOLONEY: Just one very quick one, please, sir, and 25 Mr Trotter, and it's this: Mr Trotter, did any of your 70 1 family work for Post Office? 2 A. Yes, my father-in-law worked for the Post Office and my 3 father worked for the Post Office, yes. 4 Q. Did you know a Judith Trotter working for Post Office? 5 A. The name rings a bell but she's no relation. I think -- 6 did she work with the security team? Maybe. Yes, 7 I mean, the only reason it rings a bell is because of 8 the surname but, other than that, I've no -- no 9 connection. 10 MR MOLONEY: Thank you, Mr Trotter. That's all I ask. 11 MS KENNEDY: Chair, there are no further Core Participant 12 questions. 13 SIR WYN WILLIAMS: Thank you, Mr Trotter, for attending 14 remotely to give your oral evidence and thank you for 15 making a witness statement. 16 That's it for today, Ms Kennedy? 17 MS KENNEDY: Yes, Chair. We're back tomorrow with Mr Andrew 18 Winn. 19 SIR WYN WILLIAMS: Fine. All right then. We'll see each 20 other tomorrow. Goodbye. 21 (11.54 am) 22 (Adjourned until 10.00 am the following day) 23 24 25 71 1 2 I N D E X 3 BRIAN TROTTER (affirmed) .........................1 4 Questioned by MS KENNEDY ........................1 5 Questioned by MR JACOBS .........................60 6 Questioned by MR MOLONEY ........................70 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 72