1 Friday, 20 October 2023 2 (10.28 am) 3 MS PRICE: Good morning, sir, can you see and hear 4 us? 5 SIR WYN WILLIAMS: Yes, thank you very much. 6 MS PRICE: May we please call Ms Cockett. 7 SIR WYN WILLIAMS: Yes. 8 MARIE COCKETT (affirmed) 9 Questioned by MS PRICE 10 MS PRICE: Could you confirm your full name, please, 11 Ms Cockett? 12 A. Marie Cockett. 13 Q. You should have in front of you a hard copy of 14 a witness statement in your name dated 15 May 15 2023. If you can turn to page 14 of that 16 statement, please. 17 A. Yes. 18 Q. Do you have a copy with a visible signature? 19 A. I do, yes. 20 Q. Is that your signature? 21 A. It is, yes. 22 Q. Are the contents of that statement true and 23 accurate to the best of your knowledge and 24 belief? 25 A. They are yes. 1 1 Q. For the purposes of the transcript, the 2 reference of the statement is WITN08960100. 3 Thank you for coming to the Inquiry to assist it 4 in its work and for providing the witness 5 statement that you have. As you know, I will be 6 asking questions on behalf of the Inquiry. 7 You were with the Post Office for 25 years, 8 from March 1986 to February 2011; is that right? 9 A. That's correct. 10 Q. You started as a Postal Assistant -- 11 A. Yes. 12 Q. -- and, by the time you left the Post Office, 13 you were a Senior Manager? 14 A. That's correct. 15 Q. You have set out the various roles you held with 16 the Post Office -- 17 A. Yes. 18 Q. -- at paragraph 1 of your statement. The period 19 we will be focusing on today is the period from 20 2006 to May 2009, when you held the role of 21 Branch Accounting Manager in Product and Branch 22 Accounting. You address this role at 23 paragraph 2 in your statement top the Inquiry, 24 can we have that on screen please, that's 25 WITN08960100, page 2, please. Scrolling down, 2 1 please, to paragraph 2. 2 About two-thirds of the way down. You say 3 here this is the role you took over from 4 Jennifer Robson -- 5 A. That's correct. 6 Q. -- and a role that you handed over to Alison 7 Bolsover when you moved in 2009? 8 A. That's correct. 9 Q. Dealing with your team, you say this: 10 "I managed a team of around 5 managers, who 11 managed around 50 administration staff." 12 A. That's correct. 13 Q. In relation to your team's responsibilities you 14 say this: 15 "In my role, my team and I were responsible 16 for: addressing non-conformance; recovering 17 monies owed; documenting processes; developing 18 Service Level Agreements; building and managing 19 relationships with partners (eg WHSmith) and the 20 National Federation of SubPostmasters. My main 21 focus was building relationships and documenting 22 processes and agreements. My teams managed the 23 day-to-day debt recovery and non-conformance." 24 Taking the first of the team's 25 responsibilities listed here, addressing 3 1 non-conformance, can you help us with what you 2 mean by that? 3 A. One of my teams was the -- I think it had 4 a number of different titles but I think 5 something like the Fraud and Conformance Team, 6 and they were responsible for looking at branch 7 analysis, for want of a better terminology, and 8 they looked at the number of errors, the amount 9 of debt, and all that sort of thing and, if they 10 saw that a branch was continually doing the same 11 sort of mistake, they would speak to the branch 12 and try and educate them and determine whether 13 a trainer was needed. 14 So they would work with the branches 15 individually and would also send reports out to 16 the network about the branches and the different 17 elements of errors being made, for want of 18 a better description. 19 Q. Could we have on screen, please, document 20 reference POL00084012. This is a document 21 entitled "Transaction Correction/Debt Recovery 22 Process". It is undated but appears to 23 post-date July 2006, based on the content of the 24 document. So if we can scroll down a little, 25 please, there's a reference in the middle there, 4 1 "Transaction Correction identification and 2 issue", to a document dated 17 July 2006. 3 Do you recognise this document? 4 A. No, I don't, I'm sorry. 5 Q. The part of this document which I would like to 6 ask you about is the first section under the 7 heading "Background". This reads as follows: 8 "The objective of Product and Branch 9 Accounting (P&BA) is to balance the ledgers 10 between clients and Post Office branches, in 11 order to produce accounts for clients and Post 12 Office Limited that accurately reflect the 13 transactions that are conducted over our branch 14 counters. If any discrepancies are found during 15 this process of matching the data, a Transaction 16 Correction is issued to the relevant Post Office 17 branch to rectify the account. This usually has 18 a financial impact on the branch, by either the 19 subpostmaster having to make good any shortfall 20 in cash, or receiving a credit for mistakes that 21 have been identified. 22 "If the Post Office branch makes a mistake 23 that cannot be identified and linked to 24 a client, ie too much change has been given to 25 a customer, this would result in a Branch 5 1 Discrepancy which would be realised at Branch 2 Trading. The subpostmaster would be responsible 3 for making good any losses." 4 Does this broad summary of the objective of 5 Product and Branch Accounting and the general 6 principles guiding the interrelationship between 7 branch discrepancies and transaction corrections 8 accurately reflect the position when you held 9 the role of Branch Accounting Manager between 10 2006 and 2009. 11 A. Yes, I believe that was the objective, the whole 12 of Product and Branch Accounting, not just my 13 area but the whole of the group, yes. 14 Q. Picking up on the last sentence on the second 15 paragraph that I've just read out: 16 "The subpostmaster would be responsible for 17 making good any losses." 18 This statement is made here in the context 19 of the branch making a mistake which cannot be 20 identified and linked to a client and the 21 example here given is too much change being 22 given to a customer. 23 I'd like to deal, please, with the broader 24 question of the position in relation to the 25 contractual liability of subpostmasters for 6 1 apparent shortfalls during the period you held 2 the role of Branch Accounting Manager. 3 A. Yes. 4 Q. You deal with your understanding of the 5 contractual position at paragraph 4 of your 6 statement. Could we have that on screen, 7 please. WITN08960100, page 3 of that statement, 8 please. About a third of the way down the page, 9 paragraph 4 here, you say: 10 "When I worked in the P&BA team, my 11 understanding of the contractual position was 12 that Subpostmasters were responsible for all 13 shortfalls or losses within their branch, caused 14 by negligence, carelessness or error. This is 15 my recollection from my training in 2006 and is 16 also documented in 'Losses at SPSO's: Guidelines 17 on responsibilities and recovery arrangements' 18 (understood to be issued in 1988)", with the 19 reference there and the reference to 20 paragraph 2. 21 Could we have on screen, please. The 22 document reference is POL00083939. About 23 halfway down the page is the heading 24 "Contractual Position", and the paragraph 25 underneath reads as follows: 7 1 "In strict legal teams a subpostmaster is 2 responsible for all losses caused through his 3 own: 4 "Negligence, Carelessness or Error 5 "and for losses of all kinds caused by their 6 Assistants. 7 "In practice the full contractual right to 8 recover the total loss is not always exercised 9 where losses occur, and relief, in full or part, 10 is often given even where negligence has 11 facilitated a loss. However, there is a need to 12 try to ensure, as far as possible, that SPSO 13 loss cases are dealt with uniformly and fairly 14 throughout by POC Limited." 15 There was another document which was sent to 16 you by the Inquiry for the purposes of preparing 17 your statement. This document appears to date 18 to around 1988, the one we're looking at now, so 19 well over a decade before the Horizon system was 20 rolled out. But the other document I'd like to 21 look at, please, is one that was authored by 22 you, shortly after you became Branch Accounting 23 Manager in April 2006, and it is entitled 24 "Losses Policy -- Overarching". Could we have 25 that on screen, please? The reference is 8 1 POL00030562. 2 Starting with page 2, please, about 3 two-thirds of the way down the page, we have 4 "Document Information", and we see here "Title, 5 Losses Policy for Post Office Limited branches"; 6 "Category, Standard"; "Subject, Treatment of 7 branch trading losses at Post Office branches"; 8 "Version Control", number "9"; "Author, Marie 9 Cockett, Branch Accounting and Control Manager"; 10 "Owner, Dave Miller". 11 Over the page, please. The policy was 12 managed by Lynn Hobbs and its purpose was "To 13 document the overarching policy for losses at 14 branches". We see the effective date there was 15 said to be April 2006 but, if we go over the 16 page here, we can see here from the "Version 17 Control" that version 9, this version, was still 18 in draft form. 19 A. Yeah. 20 Q. Over the page again, please. We see 21 "Section 1 -- Scope and Exclusions", and the 22 first paragraph under this heading reads as 23 follows: 24 "This policy defines Post Office Limited's 25 actions in respect of losses associated with 9 1 cash, cheques and transactional stock (whether 2 in branches, in transit or in central processing 3 locations) and in respect of the counter 4 transactions or remittance transactions 5 themselves. It also considers assets, in 6 branches, that have been partly or fully paid 7 for by Post Office Limited." 8 Then towards the bottom of the page we have 9 "Section 2 -- Liability", and this section reads 10 as follows: 11 "In general, agents are liable for all 12 losses, including counterfeits, under their 13 contractual responsibilities, DMB staff are 14 covered by the conduct code." 15 So this is your draft document and in it you 16 have stated that, in general, agents are 17 responsible for all losses, including 18 counterfeits, under their contractual 19 responsibilities. This doesn't seem to limit, 20 does it, responsibility to losses stemming from 21 negligence, carelessness or error, does it? 22 A. It doesn't, no. 23 Q. Was it, in fact, the case that, by 2006, the 24 date of this document at least, the principle 25 being applied by the Post Office was that, in 10 1 general, agents were responsible for all losses 2 occurring in branch? 3 A. No, I don't think it was. I assume -- and 4 I can't honestly remember, but I would have 5 thought the final version would have had the 6 negligence and errors within it, carelessness 7 within it. I think it's an oversight in the 8 draft. 9 Q. I'd like to turn, please, to Product and Branch 10 Accounting processes, which applied to branch 11 discrepancies and transaction corrections. 12 Could we have on screen, please, POL00085794. 13 This is a document entitled "Debt Recovery 14 Processes under Branch Trading". We can see 15 from the bottom of the page it was produced by 16 Product and Branch Accounting and is dated 17 October 2005. You say at paragraph 12 of your 18 statement to the Inquiry that, when you took 19 over as Branch Accounting Manager in 2006, this 20 document was still in use; is that right? 21 A. That's correct. 22 Q. Going over the page to page 2 of this document, 23 please, and if we can zoom in a little, please, 24 going back, please, apologies, to the 25 page before, please. The top of the next page, 11 1 please. Scrolling down just a little bit. Bit 2 further up, please. We're aiming to have the 3 first title in this document in the body of the 4 text. Thank you. 5 So we see here the title, "Debt Recovery 6 Processes under Branch Trading", and the first 7 sentence under that title reads as follows: 8 "With the introduction of Branch Trading the 9 error notice is replaced by the Transaction 10 Correction (TC), which is sent to your Horizon 11 system." 12 This document reads as though it is intended 13 to be read by subpostmasters; is that right, 14 that this was guidance for individuals? 15 A. It is prior to my time on that team but that 16 would be my assumption. 17 Q. This first sentence reflects, doesn't it, the 18 change from error notices to transaction 19 corrections, both of which you discuss at 20 paragraph 10 of your statement? 21 A. Yeah. 22 Q. Your understanding is that these were similar 23 processes, both being based on the comparison of 24 two streams of data, one stream being the cash 25 account and the other a client source or 12 1 supporting document sent by the branch; is that 2 right? 3 A. Yes, that's correct, although sometimes there 4 were three streams. So, for example, cheques to 5 processing centre, there would be the physical 6 cheques, the summary and the cash account. So 7 sometimes there were three but mainly two, and 8 certainly two through the automated system. 9 Q. Where there was a mismatch between the data 10 streams, Product and Branch Accounting would 11 look into the difference? 12 A. That's correct. 13 Q. It is your evidence at paragraph 10.3 and 10.4 14 of your statement that, where Product and Branch 15 Accounting could find a branch error 16 a transaction correction would be created and 17 sent to the branch via Horizon to correct that 18 error? 19 A. That is my understanding but I have never worked 20 on a Transaction Correction Team. That was 21 another team within Product and Branch 22 Accounting. 23 Q. Can you give us an example of the type of error 24 you're talking about here when you refer to 25 a branch error? 13 1 A. So, for example, I just mentioned cheques, I'll 2 use that as an example, if that's okay. So we 3 would have the summary of the cheques come 4 through on the system, we would have the cheques 5 sent to processor from the accounts. If the two 6 differed, we would go to the physical cheques -- 7 we used to have microfilms or images of the 8 cheques -- make sure that they added up to the 9 summary, and then we would -- if the cash 10 account was incorrect, we would then issue 11 an error to the branch with the detail of what 12 they'd actually dispatched. Did that make 13 sense? Sorry, that sounded -- 14 Q. Yes. 15 A. -- sounded confusing to me. 16 Q. Reading on, this document goes on to say: 17 "On receipt of a TC you will have 3 options: 18 "Accept and make good -- cash (or remove 19 cash) 20 "Accept and make good -- cheque 21 "Accept and Settle Centrally. 22 "NB For some TCs you may have the option to 23 seek more evidence. 24 "This leaflet explains more about the 25 process." 14 1 Then the bullet points here are addressed in 2 a bit more detail. So under the heading "Accept 3 and make good (cash or cheque)": 4 "You accept the TC and choose to make good 5 by either cash or cheque. Your cash or cheque 6 figure will automatically be adjusted. All 7 amounts up to and including £150 must be dealt 8 with in this way." 9 Then under the heading "Accept and Settle 10 Centrally": 11 "Remember: This option will only be 12 available for amounts over £150." 13 Pausing there, does that accord with your 14 understanding at the time that amounts up to and 15 including £150 had to be made good by either 16 cash or cheque, the settle centrally option not 17 being available for an amount of £150 or under? 18 A. That's my understanding, yes. 19 Q. This section goes on: 20 "By choosing the option to Accept and Settle 21 Centrally you are moving the shortage or surplus 22 to a central account held in your name. 23 "You will then receive a request for payment 24 from Product and Branch Accounting. The request 25 for payment will usually be issued on a monthly 15 1 basis. 2 "If you do not respond to this request 3 within 10 days you will be either sent 4 a reminder or will receive a phone call 5 requesting payment. If you still fail to 6 respond or settle the account within 7 days, as 7 a last resort, deductions will start from your 8 remuneration." 9 So are we right to understand from this that 10 the act of accepting a transaction correction 11 and settling centrally would, as a matter of 12 course, trigger a process whereby a request for 13 payment of the apparent discrepancy would be 14 made by P&BA, such payment usually being made -- 15 sorry, such request usually being made on 16 a monthly basis. 17 A. That was the process when I took over, yes. 18 Q. There would be a reminder if there was no 19 response within ten days and, if the person 20 still failed to respond or settle the account 21 within seven days, as a last resort, deductions 22 would start from their remuneration? 23 A. Yeah, that was my understanding when I took 24 over. There is a little bit more detail to 25 that, in that the Contract Manager or Retail 16 1 Line Manager, or whatever they were called at 2 the time, but the person in the Network that 3 looked after the branches would be involved in 4 that decision, in that discussion. 5 Q. But as a matter of principle, did the option of 6 deducting the debt, if you're calling it that, 7 from remuneration continue for the period of 8 time until 2009? 9 A. No. 10 Q. No -- 11 A. Well, yes, it did but I developed with my team 12 processes to stop the deductions from 13 remuneration if there are a challenge on the TC, 14 or help to try to see if we could find 15 a compensating transaction correction for 16 branches. I suppose when I took over this 17 process was relatively new, as you said, I think 18 was the October 2005 this came in? So part of 19 my role was really about getting to grips with 20 some of the issues, being one of them that, you 21 know, we didn't want to start taking money from 22 postmasters without absolutely making sure that 23 we'd done everything we could to help find 24 a compensating amount for them. 25 Q. It is described in this document as a "last 17 1 resort". 2 A. Yeah. 3 Q. Did it remain there as an option as a last 4 resort -- 5 A. Absolutely. 6 Q. -- until you left the role? 7 A. Yes. 8 Q. Over the page, please. Apologies, could we go 9 back to the previous page. 10 Towards the bottom of this section, "What if 11 I want to challenge a TC?" The paragraph 12 underneath this heading reads: 13 "Prior to the issue of a TC you may receive 14 a phone call from Product and Branch Accounting 15 to either clarify a transaction under 16 investigation, or discuss what appears to be 17 a discrepancy to ensure that you understand the 18 TC when it arrives. 19 "This is aimed at preventing disputes." 20 Then over the page, please: 21 "However, if you do receive a TC which you 22 do not understand or wish to challenge you 23 should do so immediately using the telephone 24 number given on the TC. If the issue can be 25 resolved at the time then you will either ..." 18 1 Then we have the options here, the first one 2 in first box here, to: 3 "Process the TC and follow the options 4 available." 5 Pausing there, those options were to make 6 good using the person's own money or to settle 7 centrally and trigger the payment request, 8 absent any further investigation? 9 A. Yeah, or to take the cash out. 10 Q. So if there was a gain rather than a loss? 11 A. Yeah. 12 Q. The second option is then set out in the second 13 box on this page: 14 "If you provide additional information, and 15 Product and Branch Accounting agree, a second TC 16 will be issued to offset the original TC. Both 17 TCs must be processed to ensure no effect on the 18 branch accounts." 19 So is it right that a second transaction 20 correction to offset or cancel the first would 21 only be issued where the caller could provide 22 additional evidence then and there? 23 A. At this point, yes. 24 Q. Looking then to the third option in the box 25 below: 19 1 "You will be courts to Accept and Settle 2 Centrally and you will be given a reference 3 number to acknowledge that further investigation 4 is due, Product and Branch Accounting will then 5 hold the amount on your central account and will 6 block recovery of that amount until the 7 investigation is complete. Once complete you 8 will be informed either that the TC has been 9 cancelled and removed from your central account 10 or that the amount will be added to your next 11 request for payment for the outstanding amount." 12 Then there's reference to Appendix A for 13 an example of request for payment. 14 So the upshot of this third option is that, 15 where a subpostmaster did not immediately have 16 evidence to challenge a transaction correction, 17 there was a block on the recovery of the amount 18 held in the central account, while further 19 investigation took place; is that right? 20 A. That's correct. 21 Q. Who conducted this further investigation? Was 22 it Product and Branch Accounting? 23 A. It would have been Product and Branch 24 Accounting, yes. 25 Q. What would that further investigation involve? 20 1 A. It depends on how much we knew. If we were 2 aware of the product or the transaction or 3 something like that, then we would direct the 4 investigation to the relevant team. If it 5 wasn't, then it would sit on one of my teams, 6 either with the Fraud and Conformance Team 7 because they looked generically across all 8 products, or with -- I had a Relationship 9 Manager work to me as well -- or with him, and 10 they would look in all the different areas of 11 the accounts to see if they could find the 12 issue. 13 Q. Was it any part of this further investigation 14 for Product and Branch Accounting to look behind 15 the Horizon data stream to determine whether the 16 data produced by the Horizon system was correct? 17 A. No. 18 Q. The sections in this leaflet we have been 19 through so far have dealt with the position 20 where the usual Product and Branch Accounting 21 process of data stream comparison has led to the 22 discovery of an apparent discrepancy in the 23 accounts? 24 A. Yeah. 25 Q. This last section, we're turning to now, appears 21 1 to relate to the situation where a subpostmaster 2 discovers an apparent discrepancy in the 3 accounts? 4 A. Yeah. 5 Q. So that heading: 6 "What are my options at the end of the 7 Branch Trading Period if a discrepancy is 8 identified and committed to local suspense?" 9 A. Yeah. 10 Q. Under that heading, it says: 11 "Branch Trading does not change the 12 requirement to make good losses nor does it 13 replace the liability for losses policy agreed 14 with the National Federation of SubPostmasters. 15 If you have a discrepancy for less than £150 you 16 will always be required to make it good by cash 17 or cheque." 18 Over to the top of the next section, please, 19 further up this page: 20 "If you have a discrepancy for over £150 and 21 you can provide evidence that you should receive 22 a TC for the error, you will need to contact the 23 NBSC helpline. They will assess your request 24 and allocate a priority rating dependent upon 25 when you are due to roll into the next Trading 22 1 Period. NBSC will then advise Product and 2 Branch Accounting to contact you. If Product 3 and Branch Accounting agree you will be asked to 4 Settle Centrally and given a reference number. 5 The amount will then be held in your central 6 account whilst the issue of the TC is pursued. 7 If a TC is issued you will be given only 8 1 option -- to Accept and Settle Centrally. 9 This option cancels the value held on your 10 central account. 11 "If after investigation, Product and Branch 12 Accounting find no discrepancy to compensate for 13 the amount held, you will be informed that the 14 item will be unblocked from your central account 15 and recovery sought via your next request for 16 payment. If you do not have evidence to support 17 your claim you will remain liable for the 18 [shortfall]." 19 Just breaking this down, where 20 a subpostmaster was challenging an apparent 21 discrepancy of over £150, that they had 22 discovered, they should first contact the 23 Network Business Support Centre helpline, so 24 that the NBSC could assess what priority rating 25 the caller should have, based on when they were 23 1 going to roll into the next trading period. 2 Pausing there, what was the length of the 3 trading period when you were Branch Accounting 4 Manager? 5 A. Initially, it was weekly but I seem to remember 6 it going to monthly but I can honestly say 7 I don't know when, whether that was at the 8 beginning or after my time or even after I'd 9 left. 10 Q. The Network Business Support Centre would then 11 get Product and Branch Accounting to call the 12 subpostmaster? 13 A. Sorry? 14 Q. The Network Business Support Centre would then 15 get the Product and Branch Accounting team to 16 call the subpostmaster? 17 A. Yes, that's correct. 18 Q. If the Product and Branch Accounting team 19 agreed, the postmaster would be allowed to 20 accept and settle centrally and the 21 subpostmaster would be given a reference 22 number -- 23 A. That's correct. 24 Q. -- and recovery would be blocked pending 25 investigation? 24 1 A. That's correct. 2 Q. Product and Branch Accounting would carry out 3 the same type of investigation, would they, as 4 would happen where a transaction correction was 5 being challenged? 6 A. That's correct, yes. 7 Q. If Product and Branch Accounting could find no 8 compensatory discrepancy in the data streams 9 they had, then the debt recovery process would 10 kick back in; is that right? 11 A. That's correct, yes. 12 Q. The last line of this leaflet says, if the 13 subpostmaster did not have evidence to support 14 their claim, they would remain liable for the 15 shortage. What was a subpostmaster to do if 16 they suspected that the figures being generated 17 by one of the data streams, the data stream 18 generated by Horizon, was wrong? 19 A. I would imagine that they would have to escalate 20 it to the Network Business Support Centre. 21 Q. Because they wouldn't have access, would they, 22 to the kind of detailed data they would need to 23 challenge the apparent discrepancy, would they? 24 A. I don't believe so. 25 Q. Product and Branch Accounting wouldn't have 25 1 access to that kind of data either, would they? 2 A. No, they wouldn't. 3 Q. The Inquiry has heard evidence of delays in the 4 transaction correction processes so that it 5 could sometimes take months for a transaction 6 correction to be issued. Do you recall that 7 being the case? 8 A. I do, and part of -- I think it's called 9 an Operating Level Agreement that's in here 10 somewhere. I developed Operating Level 11 Agreements so that we could get data out to the 12 branches as quickly as possible and, also, we 13 did a -- I'd set up a high-value process, so if 14 there was a high value transaction correction 15 that was going to go out to branches, we did the 16 investigation work beforehand and tried to at 17 least issue the two together, or understand from 18 the branch what they might have done to try to 19 make sure that we didn't leave branches with 20 just high-value errors that they're waiting 21 weeks and months for the compensating one for. 22 Q. We have just seen in the leaflet we were looking 23 at that priority for a subpostmaster being 24 contacted by Product and Branch Accounting, 25 where they were seeking a transaction 26 1 correction -- 2 A. Yeah. 3 Q. -- was determined by when they were due to roll 4 into the next trading period? 5 A. It was at that point, yes. 6 Q. The reason for this was that, before they could 7 roll over into the next trading period, 8 subpostmasters were expected to either make good 9 an apparent discrepancy by putting money in the 10 till or a cheque in the till, or they needed to 11 settle centrally? 12 A. Yeah. 13 Q. The subpostmaster faced a difficult choice, 14 didn't they, where they disputed a discrepancy 15 emerging in the trading period? Given the time 16 it took for transaction corrections to be 17 issued, an issue was unlikely to be resolved 18 before they were required to roll into the next 19 trading period? 20 A. In some instances, yes. 21 Q. So the choice was to accept and settle centrally 22 or don't roll over into the next trading period? 23 A. That's correct. 24 Q. If they chose to accept and settle centrally, 25 that meant, on the face of the accounts, 27 1 accepting a discrepancy and confirming a final 2 account for the trading period that showed that 3 discrepancy, didn't it? 4 A. Yes. 5 Q. Without Product and Branch Accounting putting 6 a block on recovery of the amount in the central 7 account pending further investigation, they 8 would be pursued for that debt? 9 A. That's correct. 10 Q. You say in your statement to the Inquiry at 11 paragraph 15 that you understood that settling 12 centrally signified acceptance of debt 13 liability, except in circumstances where further 14 investigation was being undertaken and a block 15 had been put on the debt recovery? 16 Just to be clear it's right, isn't it, that 17 further investigation by Product and Branch 18 Accounting would only lead to the cancellation 19 of that debt where a compensatory discrepancy 20 could be found on the data streams available to 21 Product and Branch Accounting -- 22 A. That's correct. 23 Q. -- which they would not find, would they, if one 24 of the data streams, the data stream produced by 25 Horizon, contained figures that were wrong? 28 1 A. No, I don't suppose they would, no. I think the 2 assumption was that the error would show up if 3 it was through careless, negligence or error, 4 which is what we believed, in providing the 5 evidence to the branch in the first place. We 6 would expect a compensating amount to come 7 through. 8 Q. That's what you were looking for -- 9 A. Absolutely. 10 Q. -- weren't you, the evidence of negligence, 11 carelessness or error? 12 A. Yeah. 13 Q. Sitting here now, do you see a problem with the 14 process and the system that was in place? 15 A. I think, initially, the initial process was very 16 black and white and I think part of what I put 17 in during my time in there was, like I said, to 18 try and negate certainly some of the big amounts 19 and make sure that we did everything we could to 20 provide the branch with the compensating errors 21 but sometimes they weren't forthcoming. 22 Q. The draft "Overarching Losses Policy" that we've 23 just looked at had number of documents embedded 24 within an appendix. 25 A. Yeah. 29 1 Q. Two of those documents dealt with the process 2 for awaiting transaction corrections. Going 3 first, please, to the document which applied to 4 "singletons", could we have this on screen, 5 please, the reference is POL00083952, and this 6 is a document that you were said to be the owner 7 of? 8 A. Yeah. 9 Q. Were you also the author of this document, can 10 you remember? 11 A. I can't remember for certain but I would suggest 12 so yes. 13 Q. There is a flowchart at the top and then the 14 process is set out in the text underneath that. 15 Just reminding ourselves that this is 16 an appendix to the April 2006 draft of the 17 "Overarching Losses Policy", and the process set 18 out here is this: 19 "Branch Trading does not change the 20 requirement to make good losses nor does it 21 replace the liability for losses policy agreed 22 with the National Federation of SubPostmasters. 23 "If you have a discrepancy for an amount 24 over £150 however, if you can provide evidence 25 that you should receive a TC for a mistake that 30 1 has been made at your branch then the process is 2 similar to now but you will not have a suspense 3 table in which to hold authorised amounts. 4 "You will need to contact the NBSC helpline 5 who having assessed your request will allocate 6 a priority rating dependent upon when you were 7 due to roll your branch trading. NBSC will then 8 advise Product and Branch Accounting to ring 9 you. If agreed you will be then asked to accept 10 and settle centrally the amount of the 11 discrepancy and be given a reference number 12 (similar to the process for TC queries). The 13 amount will then be held on your account whilst 14 the issue of appropriate TC is pursued. Once 15 the TC is available you will be given only 16 1 option -- to accept and settle centrally. By 17 choosing this option you then effectively cancel 18 the debt held on your account." 19 So we see there, don't we, a reference to 20 not having a suspense table in which to hold 21 authorised amounts. Is this a reflection of the 22 availability of local suspense for 23 subpostmasters to hold amounts in, which was 24 removed and replaced by the settle centrally 25 option? 31 1 A. I honestly can't remember, I'm sorry. It would 2 appear so. 3 Q. Apart from this reference, the process remains 4 unchanged, doesn't it, from that set out in the 5 leaflet we were just looking at? 6 A. It does, yeah. 7 Q. Do you recall the process -- speaking 8 specifically of this process -- changing in any 9 significant way before you left the role of 10 Branch Accounting Manager in 2009? 11 A. In terms of this process, no. As I said 12 earlier, we tried to be pro-active so that it 13 didn't get to this point. 14 Q. Once someone had chosen to settle centrally and 15 there was no block in place to recovery the 16 amount held centrally, what process was followed 17 to recover the debt? 18 A. From my memory, we would send a statement of 19 debt and request for payment, either by cheque 20 or credit card. We would then send a reminder 21 and contact the branch's -- and, again, forgive 22 me, I don't know the terminology at the time but 23 it was Contract Manager, Retail Line Manager, 24 Branch District Manager, or whatever, to ask for 25 their opinion on the fact that we hadn't had 32 1 a response and, ultimately, they gave the okay 2 to deduct from remuneration, if that's where we 3 got to. 4 But, hopefully, in most instances, I would 5 say we would have spoken to the branch and 6 actually got a response from them. 7 Q. In what circumstances would you reference a case 8 to the Legal team? 9 A. Only if there was a debt from the former 10 subpostmaster who no longer had a branch and 11 therefore no longer had remuneration. We would 12 send statements, letters, reminders and then 13 ultimately pass a pack on to the Legal team to 14 make -- to decide whether or not there was 15 a case to answer. 16 Q. What level of involvement did you have in cases 17 once they had been referred to the Legal team 18 and civil proceedings for recovery of the debt 19 were issued? 20 A. Very little. I wasn't senior enough. I had to 21 make sure my teams got the block on any debt 22 recovery. I had to make sure that my teams 23 provided evidence as required. My line manager, 24 Rod Ismay, took the lead on a lot of the 25 discussions with Legal. I may well have 33 1 answered a couple of emails or got involved if 2 Rod was absent. 3 Q. I'd like to turn, please, to a meeting which 4 took place on 6 December 2005 about Horizon 5 integrity, a meeting which you attended. Could 6 we have this on screen, please, POL00142539. 7 This is the meeting agenda, we can see at 8 the top. We can see the date there, 6 December 9 2005. We can see the attendees for the meeting: 10 Keith Baines, Fujitsu Contract Manager. Do you 11 remember Keith Baines? 12 A. I remember the name. That's about as much as 13 I can remember, sorry. 14 Q. Then you were listed and the role description 15 here is Project Manager, Finance. Does this 16 description mean you attended this meeting 17 before you took up the Branch Accounting Manager 18 role -- 19 A. That is correct. 20 Q. -- when you were in project management in 21 Finance? 22 A. That's correct. 23 Q. Other attendees at the meeting included John 24 Legg, Agency Contracts manager; Jennifer Robson, 25 who was your predecessor, wasn't she, in the 34 1 Branch Accounting Manager role? 2 A. That's correct. 3 Q. Mandy Talbot, who is described as Litigation 4 Team Leader from Legal Services. Do you 5 remember Mandy Talbot? 6 A. Again, I remember the name and I would have 7 known she was Legal but that's it, really. 8 Q. Graham Ward from the Investigation Team, further 9 down, second to last. So representation at this 10 meeting from a range of teams within the Post 11 Office? 12 A. Yes. 13 Q. We see the subject of the meeting, "Horizon 14 Integrity", about halfway down the page. Then 15 there is some background to the meeting: 16 "There have been several recent cases where 17 subpostmasters have cited errors in the Horizon 18 system as explanations for discrepancies in 19 their accounts -- either as part of a challenge 20 against termination of their contracts, or in 21 challenging the Post Office's right to recover 22 error notices/transaction corrections from their 23 remuneration. 24 "Recently, a letter was published in 'The 25 SubPostmaster' in November (see enclosure) 35 1 asking readers to send in details of incidents 2 where they believe that Horizon has caused 3 errors in their accounts. Lawyers acting on 4 behalf of a subpostmaster currently in dispute 5 with Post Office have written stating they are 6 contemplating a joint action on behalf of 7 a number of current and former subpostmasters. 8 This would challenge the accounting integrity of 9 the Horizon system and Post Office's right to 10 make transaction corrections and recover 11 resulting debts based on Horizon data. 12 "In one past case (Cleveleys branch), Post 13 Office settled out of court following an adverse 14 report on Horizon's potential to cause errors 15 from an expert appointed by the court. Fujitsu 16 advised that the report was not well founded, 17 but Post Office and Fujitsu were not able to 18 persuade the expert to change it. This report 19 was largely based on a review of Helpdesk logs, 20 since it related to events more than 18 months 21 prior to the case, and Horizon transaction data 22 was retained for 18 months only. (It is now 23 retained indefinitely.) 24 "There are well-defined (though costly) 25 procedures for analysing Horizon data and 36 1 getting evidence and witnesses from Fujitsu in 2 support of investigations for potential criminal 3 cases. This is not so for civil cases (unless 4 there has been a related investigation) and 5 external lawyers acting on Post Office's behalf 6 have found it difficult to obtain information of 7 sufficient quality from Post Office in 8 timescales needed for these cases. No one seems 9 to hold budget to fund provision of such 10 information. 11 "The above was discussed at a meeting called 12 by Dave Smith on 25 November and as a result 13 urgent actions have been taken to support 14 current live cases, and this workshop was 15 organised to recommend further actions to reduce 16 this risk area in future." 17 Under "Meeting purpose", we have this: 18 "To review the above issues and recommend on 19 the following:" 20 "[First] Who manages dealings with 21 subpostmasters and their lawyers relating to 22 actual or potential civil cases? What processes 23 are required to identify as early as possible 24 those cases that with a Horizon aspect? Who 25 needs to be involved in such cases, and how will 37 1 they be coordinated? 2 "[Secondly] Are there any new processes 3 required with Fujitsu to obtain data, analysis 4 reports or witness statements for civil cases? 5 "[Thirdly] Is there a need for 6 an independent expert to be appointed in advance 7 who could on request provide evidence to the 8 court in such cases? If so, what exactly would 9 the expert's role be, what qualifications and 10 qualities are needed in such an expert, and how 11 would we go about appointing one? What 12 preliminary work would be required by the expert 13 to 'get up to speed'? 14 "[Fourthly] Who will act as the client 15 briefing external lawyers and facilitating their 16 information in these cases? 17 "[Fifthly] What are the budget implications 18 of the above?" 19 We then see an agenda setting out some 20 timings. 21 Going, please, then to the notes of the 22 meeting itself. Could we have on screen, 23 please, POL00119895. About halfway down the 24 page, please, we have "Findings". The first 25 finding was this: 38 1 "There is no generally understood process 2 for identifying emerging cases in which the 3 integrity of accounting information produced by 4 Horizon may become an issue. 5 "[Secondly] There are a number of channels 6 by which such cases may enter Post Office (see 7 flip chart list) and there is no process making 8 information about them available to all relevant 9 functions. This increases the risk that 10 different parts of the business may be dealing 11 with the same issue and not coordinate 12 responses." 13 So there is a recognition here, isn't there, 14 that there was no process of collating 15 information about cases in which the integrity 16 of accounting information produced by Horizon 17 was being raised or to make it available to all 18 functions across the Post Office? 19 A. That's what it says, yes. 20 Q. The risk identified here was that there may not 21 be a coordinated response but there was another 22 risk, wasn't there, that the whole picture was 23 not being assessed by anyone within the Post 24 Office, so the number of people raising the 25 issue overall was not being assessed. Did you 39 1 recognise that at the time as a risk? 2 A. No, not at all. 3 Q. Was there any discussion at the time of that 4 risk? 5 A. I don't remember this meeting at all, I'm 6 terribly sorry. 7 Q. Point 3 deals with the audit query requests 8 which could be made of Fujitsu and the fact that 9 interpretation of the data was not simple and 10 required a considerable level of understanding 11 and technical skill. 12 Point 4, over the page, please. This deals 13 with the high price of Fujitsu providing such 14 data. It says this: 15 "Fujitsu's price for providing the data and 16 for skilled resource to analyse and report on it 17 is high, and the capacity provided in the 18 contract currently is fully used to support 19 investigations relating to potential criminal 20 cases." 21 Then point 5: 22 "To date, the number of cases in which the 23 integrity of Horizon data has been an issue is 24 small; however, recent correspondence in The 25 SubPostmaster may well cause an increase; also 40 1 there may also be an effect from the 2 introduction of transaction corrections, 3 replacing error notices." 4 Pausing here, why would there be an effect 5 from the introduction of transaction corrections 6 replacing error notices on the number of cases 7 in which the integrity of Horizon data was being 8 raised? 9 A. I don't know, I'm sorry. I don't remember this 10 meeting or any outcome from it. I don't 11 understand why there would be an increase. 12 Q. Moving to point 8: 13 "If all potential cases were to require 14 Horizon data to be analysed early in the 15 process, then the workload would be 16 considerable -- and much would later prove 17 unnecessary; currently there are around 18 12 suspensions per week, and a significant 19 proportion of them will relate to financial 20 discrepancies. Most of these are subsequently 21 settled by agreement, or are not contested." 22 Point 9: 23 "Where a case does go to court, it is 24 essential that Post Office is able to refute any 25 suggestion that Horizon is unreliable (in 41 1 general) or that it could have caused specific 2 losses to the subpostmaster bringing the case. 3 The evidence needed for these 2 points will be 4 different." 5 Paragraphs 10 to 13 deal with the type of 6 expert evidence which might be needed. Then 7 point 14: 8 "The Castleton (Marine Drive branch) case, 9 scheduled for 7 February is the first of the 10 current cases that may require expert testimony; 11 this will not be needed on 7 February, but could 12 be needed next time this case is in court; 13 internal analysis of the data by POL and Fujitsu 14 will be required before 7 February to confirm 15 that POL's position is valid." 16 Was this the first time that you became 17 aware of the Castleton case or do you think you 18 may have been made aware of it before? 19 A. As you quite rightly said at the beginning, 20 I was at this meeting as Project Manager, so 21 I wouldn't have needed to know -- well, 22 I wouldn't have needed to know about it then, 23 but I certainly -- I'd heard the name and I'd 24 certainly been -- exchange of emails but all 25 after this point. So I would suggest that this 42 1 was probably the first time. 2 Q. Turning then, to the "Recommendations", first: 3 "A coordination role should be established 4 to maintain a list of all current civil cases 5 and potential civil cases where accuracy of 6 Horizon accounting information may be an issue, 7 and ensure that all relevant business functions 8 are made aware of these cases." 9 Was a coordination role established, as far 10 as you know? 11 A. Not as far as I'm aware. 12 Q. Then point 2: 13 "Briefing is required -- primarily for the 14 Contracts and Services Managers, but for all 15 staff dealing with subpostmasters -- setting out 16 business policy, lines to take and how to 17 identify potential emerging cases." 18 What were the lines to take? 19 A. I don't know, I'm sorry. I really don't 20 remember this meeting or any subsequent actions 21 from it. 22 Q. Point 3 deals with who should analyse the data 23 from Fujitsu. 24 Point 4 -- over the page, please -- then 25 recommends the appointment of an external expert 43 1 with a proposal that discussions with Fujitsu 2 should be initiated on this role. 3 Then at point 5: 4 "There are some issues relating to the BIMS 5 process, Post Office staff dealing with the BIMS 6 reports from Fujitsu are sometimes unclear what 7 action is appropriate in response to the report, 8 and no contact details are provided for 9 clarification to be obtained. These reports can 10 result in transaction corrections being issued 11 and this may be challenged by the 12 subpostmaster." 13 Can you recall discussion of this last point 14 now at all? 15 A. No, not at all. 16 Q. It appears to have led to an action point for 17 Jennifer Robson and you -- 18 A. Yeah. 19 Q. -- under "Specific Actions". The first of 20 these: 21 "JR/MC -- to look at internal POL issues on 22 handling of BIMS reports from Fujitsu and brief 23 DH on issues that need to be raised with 24 Fujitsu." 25 "DH", was that -- 44 1 A. My guess would be it would be Dave Hulbert. 2 Q. What were the adverse consequences of Post 3 Office staff not knowing what to do with the 4 BIMS report? 5 A. I really don't know. I don't know what the BIMS 6 report is. I can't remember that at all. Like 7 I say, I can't remember the actions from this. 8 I can't remember doing that at all. I'm sorry; 9 it's such a long time ago. 10 Q. Does it follow that you can't help with what 11 involvement you had on this action point after 12 the meeting? 13 A. I don't remember any involvement at all. 14 Q. So you don't know how this was taken forwards, 15 if at all? 16 A. No, I don't I'm sorry. 17 MS PAGE: We needn't go to it but, for the record, 18 the flip charts that are referred to in this 19 meeting are at reference POL00119896. 20 Sir, I wonder if that might be the 21 appropriate moment for the morning break. 22 SIR WYN WILLIAMS: I was just completing my note. 23 Yes, that's fine. What time shall we 24 recommence? 25 MS PRICE: At 11.50, please, sir. 45 1 SIR WYN WILLIAMS: Yes, that's fine. 2 (11.30 am) 3 (A short break) 4 (11.49 am) 5 MS PRICE: Hello, sir. Can you see and hear us? 6 SIR WYN WILLIAMS: Yes, I can, thank you. 7 MS PRICE: Ms Cockett, the meeting we have just been 8 discussing, there was a reference to the 9 Castleton case at that meeting, and you say in 10 your statement to the Inquiry at paragraph 35 11 that you have no recollection of the civil cases 12 which were listed in the request from the 13 Inquiry, one of those cases was the Castleton 14 case. 15 There are a number of emails relating to 16 that case, which you were provided with at the 17 time that you made your statement, but, more 18 recently, you've been provided with some further 19 emails showing your involvement on an email 20 circulation list and some involvement in 21 discussions internally within the Post Office of 22 the Castleton case and you've had a chance to 23 look at those emails now, haven't you? 24 A. That's correct, yes. 25 Q. I'd like to start, please, with an email from 46 1 Mandy Talbot, dated 1 March 2006. Could we have 2 this on screen, please, the reference is 3 POL00071202, and it's page 9 of that document, 4 please. The email is from Mandy Talbot, we can 5 see the date there, 1 March 2006, and a couple 6 of lines down from that we can see your name as 7 a recipient, can't we? 8 A. We can, yes. 9 Q. About halfway down the page, the first line of 10 that email, Mandy Talbot refers to the meeting 11 in December 2005 and explains that she is 12 bringing those who attended up to date with the 13 current state of play. She asks for a progress 14 update on the business case for the appointment 15 of someone to analyse data from Fujitsu for the 16 benefit of the Post Office. 17 Then four paragraphs down she addresses the 18 Castleton case. She then proceeds to set out in 19 some detail, going over two more pages, the 20 details of the case. When you saw this email, 21 it was one of the ones provided to you when you 22 were given a request for a statement, when you 23 saw it then, did you recall Mr Castleton's case 24 at all? 25 A. No, I recall the name, but I would have been 47 1 involved very minimally, I wasn't senior enough 2 to make any decisions on it and I don't 3 recognise this email at all. Clearly, I had it 4 and saw it but I don't recognise it, I'm sorry. 5 Q. Mandy Talbot also raised some other cases in 6 this email. Could we go, please, to page 11 of 7 this document, about two-thirds of the way down. 8 The case of Bajaj, current postmaster at Torquay 9 Road. We see there reference to the case: 10 "... complaining about the HORIZON system 11 since Christmas 2004 and has alleged that it has 12 manufactured errors which have resulted in him 13 to date paying 14,000 to POL, which he claims 14 was not justified." 15 Then, over the page, please, about a third 16 of the way down: 17 "New case -- Bilkhu, postmaster at Bowburn 18 Post Office." 19 Then five paragraphs down: 20 "Keith and Dave Hulbert have brought the 21 case of Hughie Noel Thomas to our attention as 22 being yet another discipline case where HORIZON 23 is being blamed." 24 So you were, by this email, being told about 25 four different cases where there was a challenge 48 1 to the integrity of the Horizon data being used 2 by the Post Office to recover money from 3 subpostmasters. It may follow from the fact 4 that you don't remember this email now but did 5 this concern you at all, that there were four 6 cases in which this issue was being raised? 7 A. No, because I trusted the people who worked with 8 Horizon, ie Keith Baines and Dave Hulbert, to do 9 the analysis and tell us whether there were 10 a problem, and they kept saying that the system 11 was robust and there were no issues. 12 Q. Quite apart from whether you remember this 13 particular email, do you remember there being 14 cases like this? 15 A. No, I don't, I'm sorry. 16 Q. You don't remember being made aware of cases 17 where the integrity of Horizon was being 18 challenged? 19 A. I don't remember specific cases, no, and 20 I certainly don't remember any outcomes to say 21 that Horizon was less than robust. 22 Q. Setting aside the specifics of any cases, in 23 general terms, were you aware of there being 24 cases like this, where the integrity of Horizon 25 was being challenged? 49 1 A. I think, given the fact that I was copied in on 2 these emails, yes, I must have been aware of but 3 I don't remember them now. 4 Q. When it came to the question of whether the 5 Castleton case should be settled, you were 6 included on some correspondence relating to 7 this, weren't you? 8 A. Yes. 9 Q. We'll come to that in a moment but could we 10 first have on screen, please, document reference 11 POL00158374. This is one of the documents that 12 you have seen very recently and it appears in 13 a somewhat odd format. It's unclear exactly who 14 it is being sent to or on what date. But it 15 appears to be an email from you; would you 16 agree? 17 A. Yes, that's correct. 18 Q. It reads as follows: 19 "Both 20 "Just to let you know I have just spoken 21 with Mandy Talbot regarding Marine Drive and 22 agreed we will push back to him asking for full 23 payment and a waiver saying there is nothing is 24 wrong with Horizon data. 25 "Watch this space. 50 1 "Cheers 2 "Marie." 3 Do you remember having a discussion with 4 Mandy Talbot about the settlement terms of the 5 Castleton case now. 6 A. No, I don't, I'm sorry. 7 Q. On this case, and cases of this type, what role 8 would Mandy Talbot typically play? 9 A. From my memory, Mandy Talbot was leading the 10 legal cases. She was our contact in Legal. 11 That's as much as I know, really. That's as 12 much as I can remember, I'm sorry. 13 Q. What was the reason for wanting a waiver which 14 said that there was nothing wrong with Horizon 15 data? 16 A. My recollection is that we had not 17 established -- sorry, we were still being told 18 that Horizon was robust and, therefore, that's 19 why we wanted a waiver, because there wasn't 20 anything that we'd found that was wrong with the 21 Horizon data. That was my understanding at that 22 time. 23 Q. Given that you knew there were a number of cases 24 where the integrity of Horizon data was being 25 challenged, did you feel it was appropriate for 51 1 the Post Office to be seeking such a waiver? 2 A. Clearly, I did because that's what I've put 3 there. Again, we were just being told 4 categorically that the Horizon data was robust. 5 Q. Where was that message coming from? 6 A. I was -- I would guess it would be coming from 7 the IT guys, so such as Dave Hulbert, Keith 8 Baines, from Fujitsu. That would be my 9 understanding. They were our main contacts. 10 Q. Could we have on screen, please, POL00158375. 11 Starting, please, about halfway down the page. 12 This is an email from Mandy Talbot to a number 13 of people, 10 November 2006. Richard Barker is 14 the first recipient of this email. Who was he? 15 A. I'm honestly not sure. There was two Richard 16 Barkers, one -- no, there wasn't. No, sorry, 17 I'm getting confused. I'm not sure, he was 18 certainly one of the top Senior Managers. I'm 19 not sure what he was responsible for. 20 Q. We have Keith Baines, Rod Ismay, you, Clare 21 Wardle, Biddy Wyles and Stephen Dilley as the 22 other recipients, and this email reads as 23 follows -- I should say the subject line is 24 "Castleton's counter of PO v Castleton URGENT 25 URGENT", and the body of the email reads: 52 1 "You will all be pleased to know that the 2 solicitors acting for Castleton have 3 substantially accepted our counter proposal. 4 I attach a copy of their letter. 5 "Castleton is not prepared to have judgment 6 entered against him because he claims it would 7 prejudice his future career prospects and so the 8 claim will be settled by way of a Tomlin Order. 9 This means that if anybody searched the Court 10 records all they would see is a record that the 11 claim was resolved but the detail of the same is 12 kept private. 13 "Castleton is prepared to make an open 14 statement that POL can use as it chooses 15 exonerating the HORIZON system. I now need your 16 assistance over the form of wording that POL 17 would like to see in that statement. 18 "I have prepared a short statement but would 19 be very grateful for any improvements which you 20 can suggest. We need to have a settled form of 21 words to go back to Castleton's solicitors as 22 soon as possible. This settlement is still 23 without prejudice and does not formally conclude 24 the action until it is signed so we must 25 endeavour to get it signed as soon as possible." 53 1 Over the page, please, and this is the 2 wording being proposed: 3 "'I, Mr L Castleton the former postmaster at 4 Marine Drive Post Office admit that a sum of 5 money was owed by me to Post Office Limited as 6 a result of errors which arose whilst I was the 7 postmaster at the above office. I had though 8 that this debt arose due to a malfunction of the 9 HORIZON system but I know accept that I was 10 mistaken and that the debt arose out of human 11 error. I declare that the HORIZON system did 12 not contribute to the errors in any way and 13 formally withdraw all statements I made to the 14 contrary." 15 If we can go back, please, to the top of the 16 first page of this document. This appears to be 17 a reply from you to Mandy Talbot, and it reads: 18 "Mandy 19 "Looks ok to me 20 "Regards 21 "Marie." 22 Do you recall commenting on the draft waiver 23 being proposed in this case? 24 A. No, I don't. I'm sorry. 25 Q. But it appears from this that you did comment on 54 1 it and considered that that wording that we've 2 just looked at was acceptable? 3 A. It does, yeah. 4 Q. Would you accept now that proposing that wording 5 in the circumstances of Mr Castleton's case was 6 not an appropriate thing to do? 7 A. I don't know, is the answer. I really don't 8 know. I'm not a legal person and I don't know 9 if that's the right wording or not. There's 10 certainly some grammatical errors in it but 11 that's another story. 12 Q. You say at paragraph 38 of your statement to the 13 Inquiry that during your time working for the 14 Post Office you were not aware and did not have 15 any concerns regarding the robustness of the 16 Horizon IT System and saw no evidence of bugs, 17 errors or defects. Could we have on screen, 18 please, another document which was received by 19 the Inquiry very recently and you have seen very 20 recently. The reference is POL00158371, 21 starting, please, with the email from Dawn 22 Brooks, dated 13 December 2006, sent to Dave 23 Lancashire and copied to you. We see the cc, to 24 you. 25 A. Yes. 55 1 Q. Who was Dave Lancashire? 2 A. Dave Lancashire worked on one of my teams, 3 reporting to Carol King, and they managed the 4 discrepancies in remittances -- in cash 5 remittances between the branches and the cash 6 centres. 7 Q. The subject of this email is "Mismatch of cash 8 holdings at some branches between Flexible 9 Planning and POLFS". 10 A. Yes. 11 Q. If you can just decode that acronym for us, 12 "POLFS"? 13 A. POLFS was -- basically, it was the back end 14 financial system to Horizon. So it was POL's 15 financial system, basically. So it was what 16 Horizon interfaced into. 17 Q. The email reads: 18 "Dave 19 "I have updated Doug based on the 20 information you have provided, sounds like good 21 news. My concern is that there remain a number 22 of anomalies which clearly require 23 investigation. 24 "In readiness for period 9 reporting, and 25 Carol's return, could we pull together some kind 56 1 of summary of the offices where we still have 2 difference, the 49 in question. I think we need 3 to understand ..." 4 Then there are number of bullet points: 5 "Month on month is the value of the 6 difference consistent, or does the difference 7 vary over time? Could your summary include 8 trend analysis from period 3 onwards. 9 "Can we isolate this to a particular day or 10 transaction/rem? 11 "What is the overall value of the 12 difference, is Flexible Planning greater than 13 POLFS or the other way around? 14 "What is the impact of this difference? Do 15 we need to make any kind of provision for this 16 difference? Without knowing the value of the 17 difference I'm not sure if its material. 18 "If you could pull this together over the 19 next few days then could you go through this 20 with Carol or Marie, in the first instance or 21 myself if they are not around. My understanding 22 is that Carol is aiming to come into work on 23 Monday although this is not 100% certain at this 24 stage. We need a decision around provisions by 25 around next Wednesday so if Carol does not come 57 1 in you may wish to speak to Marie and walk her 2 through your findings." 3 Going back up to the top of page 1 of this 4 document, this is then forwarded to Cathy. Is 5 that Catherine MacDonald? 6 A. I presume it is Catherine MacDonald but I don't 7 know why Cathy was involved in it. I wonder if 8 it should have been Carol and was a typing error 9 but I can't see the people it was sent to, so 10 ... 11 Q. And to you. 12 A. Yeah. 13 Q. It reads: 14 "See the attached, period 08 (26/11/2006) 15 Flexible Planning v POLFS differences. 16 "I have been unable to isolate the 17 particular day, only the period. Also see the 18 emails from Anne Chambers (Fujitsu) regarding 19 the differences. 20 "Dave." 21 You were sent the lengthy email chain 22 underneath the emails we've just looked at. 23 A. Yeah. 24 Q. Going to page 7 of this document, please, we see 25 here an email from Sujith Pooja to Julie Dart, 58 1 dated 18 July 2006. 2 Did you know these two individuals? 3 A. Julie Dart, yes; the other lady, no. 4 Q. Scrolling down to the body of the email, please. 5 This email, several lines down starts: 6 "There was a bug in S60 where EOD failed to 7 summarise correctly and left the balances set to 8 incorrect values." 9 Scrolling a bit further down, please. We 10 see in the penultimate paragraph "A fix to 11 correct this was applied", with some details 12 with that. 13 Did you recognise at the time that the 14 emails you were being sent related or appeared 15 to relate to a bug in the system and a fix. 16 A. I don't remember the emails at all. Certainly 17 Carol King would have dealt with this on my 18 behalf. She was the expert in that area. But 19 I -- interpreting this today as I've read it 20 this morning, I'm not sure the problem was 21 Horizon because the flexible planning was the 22 remittance -- I believe it was in the remittance 23 centres and it was basically advising them to 24 send cash to the branch because they were low, 25 and I think it was that that was the error but 59 1 I'm -- like I said, I don't remember the email 2 but that's my interpretation of that. 3 Q. Okay. So does this alter your evidence at all 4 in paragraph 38 of your statement, in terms 5 of -- 6 A. No, because I don't think it's Horizon. 7 MS PRICE: Okay. 8 Sir, those are all the questions that have 9 for Ms Cockett. I'm looking around the room to 10 see ... 11 It doesn't appear that there are any 12 questions from Core Participants. 13 SIR WYN WILLIAMS: All right. 14 Well, thank you, Ms Cockett, for providing 15 a witness statement and for giving oral evidence 16 and I think that brings this session to 17 a conclusion; is that right? 18 MS PRICE: Yes, sir, that's correct. 19 SIR WYN WILLIAMS: We now have a break of two weeks, 20 so that everybody can draw breath and get ready 21 for the next set of hearings. Is that also 22 correct, Ms Price? 23 MS PRICE: Yes, sir. 24 SIR WYN WILLIAMS: All right, well, I'd just like to 25 thank everyone in the room for helping to ensure 60 1 that the sessions which began in the middle of 2 September have gone as smoothly as they have and 3 we've kept on track, so to speak. So thank you 4 all for your cooperation, and I will see you in 5 a fortnight's time or thereabouts. 6 THE WITNESS: Thank you, sir. 7 (12.12 pm) 8 (The hearing adjourned until 9 Tuesday, 7 November 2023) 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 61 I N D E X MARIE COCKETT (affirmed) ......................1 Questioned by MS PRICE ........................1 62