1 Thursday, 16 May 2024 2 (9.45 am) 3 MS PRICE: Good morning, sir, can you see and hear us? 4 SIR WYN WILLIAMS: Yes, thank you very much. 5 MS PRICE: May we please call Ms Sewell. 6 SIR WYN WILLIAMS: Yes. 7 LESLEY JESSIE SEWELL (sworn) 8 Questioned by MS PRICE 9 SIR WYN WILLIAMS: Ms Sewell, I appreciate this may be 10 upsetting for you. Ms Price will ask you a number of 11 questions in a proper and sensible manner but if, at any 12 time, you feel you need a break, just let me know, all 13 right? 14 THE WITNESS: Thank you, sir. 15 MS PRICE: Can you confirm your full name, please, 16 Ms Sewell? 17 A. Lesley Jessie Sewell. 18 Q. Thank you for coming to the Inquiry to assist it in its 19 work. As you know, my name is Emma Price and I ask you 20 questions on behalf of the Inquiry. 21 You should have in front of you a hard copy of your 22 witness statement; do you have that? 23 A. Yes. 24 Q. It is dated 16 April 2024, and if you could turn to 25 page 41 of that document, please. 1 1 A. Yes. 2 Q. Is that your signature? 3 A. It is. 4 Q. Are the contents of that statement true to the best of 5 your knowledge and belief? 6 A. They are. 7 Q. That witness statement, for which the reference is 8 WITN00840100 is now in evidence and will be published on 9 the Inquiry's website in due course? 10 I'd like to start, please, with your professional 11 background and the roles you held at the Post Office. 12 A. Yes. 13 Q. As you set out in your statement, your bachelor's degree 14 was applied computing? 15 A. That's right. 16 Q. You then completed an MBA? 17 A. That's right. 18 Q. You started your career as a trainee computer operator 19 in Newcastle Polytechnic's Computing Department; is that 20 right? 21 A. I did. 22 Q. Then from 1985 to 2010 you worked for Northern Rock? 23 A. I did. 24 Q. Is it right that all of your roles at Northern Rock were 25 in IT? 2 1 A. That's correct. 2 Q. You started as a Trainee Programmer and your final role 3 was Managing Director of IT? 4 A. That's correct. 5 Q. You say in your statement that in your 25 years at 6 Northern Rock you led many major IT programmes. What 7 did leading such programmes involve? 8 A. So I led programmes for -- a good example of that would 9 be full rollout of a workflow solution across the whole 10 of the business. So I would take a leading role in 11 that, in sponsoring them. 12 Q. Whilst you were at Northern Rock, were you ever involved 13 in overseeing, developing or managing any Electronic 14 Point of Sale systems? 15 A. The only systems would have been branch systems. 16 Q. The same question in relation to accounting systems? 17 A. Yes, finance and treasury systems. 18 Q. You joined the Post Office in April 2010; is that right? 19 A. That's correct. 20 Q. Your role when you joined was Head of IT and Change? 21 A. That's correct. 22 Q. Who did you report to in that role? 23 A. Mike Young. 24 Q. Whose position at the time was? 25 A. I believe it was Chief Operating Officer. 3 1 Q. You say in your statement you were Head of IT until the 2 first or second quarter of 2012 when you were asked to 3 be interim Chief Operating Officer after Mike Young's 4 departure; is that right? 5 A. That's correct. 6 Q. Roughly how long did you remain in that interim role? 7 A. It was for a very short period. I think probably 8 between three and five months maximum. 9 Q. When you took up that interim role, did you become part 10 of the Executive Committee? 11 A. Yes, I did. 12 Q. By the end of 2012, you had taken up the role of Chief 13 Information Officer; is that right? 14 A. Yes. 15 Q. Did you remain on the Executive Committee as Chief 16 Information Officer? 17 A. I did, until the end of 2014. 18 Q. What happened at the end of 2014 that meant you were no 19 longer on the Executive Committee? 20 A. There was a restructure and we had a Group Executive 21 which was created. 22 Q. As Chief Information Officer, you were initially 23 reporting to Sue Barton, the Post Office Strategy 24 Director; is that right? 25 A. That's correct. 4 1 Q. Until she left at the end of 2013, after which time you 2 were reported to the Chief Financial Officer, Chris Day? 3 A. That's correct. 4 Q. At paragraph 9 of your statement, you set out a number 5 of additional responsibilities for Information Security, 6 which you took on from late 2013 into 2014, and these 7 included commissioning a Deloitte maturity review to 8 inform the information security operating model? 9 A. That's right. 10 Q. Was this Deloitte review the Project Zebra review that 11 you have referred to elsewhere in your statement? 12 A. No, it wasn't. It was completely separate. 13 Q. Okay. Can you help a little bit with what that maturity 14 review involved? 15 A. It was basically looking at current responsibilities and 16 scope for information security and looking at what was 17 in place, and determining, on a standard information 18 security maturity model, where Post Office actually sat 19 on that. 20 Q. You have identified members of your team when you were 21 Chief Information Officer at paragraph 10 of your 22 statement. Could we have that on screen, please. It's 23 page 6 of the statement. Here you say this: 24 "As CIO I brought in an experienced IT Programme 25 Lead/Transformation Director, Neil Wilkinson, who was 5 1 responsible for delivering separation and then more 2 broadly the IT Transformation (procurements and 3 delivery). I also brought in a Chief Technology 4 Officer, Paul Bleasby, who led the architecture team and 5 was the Chief Architect of [Post Office Limited's] IT 6 systems. He worked closely with third party suppliers 7 (including Fujitsu) and the wider business on developing 8 the IT strategy and delivering aspects of the IT 9 Transformation Programme. I would rely on Paul for 10 technical input. David Hulbert ..." 11 Am I pronouncing that correctly? 12 A. That's correct. 13 Q. "... was the copied in Head of Service responsible for 14 the day-to-day operations of all the IT services 15 (including Horizon). All directly reported to me, in 16 addition to a Head of Business Relationships, Head of 17 Quality and Standards, Head of Managed Services and Head 18 of Projects." 19 Did you have regular meetings with your direct 20 reports? 21 A. Yes. 22 Q. How often would you meet with them? 23 A. From memory, I think weekly. 24 Q. You say in your statement at paragraph 6 that you became 25 Operations Director in addition to Chief Information 6 1 Officer, following a restructure in early 2015 -- 2 A. That's correct. 3 Q. -- and, from that point, you reported to the new Chief 4 Financial Officer, Alisdair Cameron? 5 A. Yes. 6 Q. Whilst reporting to Alisdair Cameron in 2015, you took 7 on the additional responsibility of back office 8 activities for Product and Branch Accounting and HR; is 9 that right? 10 A. That's correct. 11 Q. You left the Post Office in November 2015, following 12 your resignation in early June 2015? 13 A. That's correct. 14 Q. Turning, please, to the substance of your roles with the 15 Post Office, you describe your first role, the Head of 16 IT and Change role, at paragraph 7. That's page 3. You 17 say: 18 "On joining POL, my understanding was that I had 19 been brought in to oversee the separation from RMG and 20 the resulting IT transformation and to build the IT 21 capability post-separation." 22 Further down this paragraph, about five lines up 23 from the bottom, you say this: 24 "My objective was, with the support of the 25 executives and the Board, to build a holistic IT 7 1 strategy for separation. Horizon and the relationship 2 with Fujitsu was one part of the overall IT strategy." 3 Focusing first on what you were told about Horizon 4 when you took up the Head of IT and Change role in 2010, 5 could we go, please, to paragraph 12 of the statement, 6 that's page 7. You say here: 7 "I had no knowledge of Horizon before joining [Post 8 Office Limited] other than at the interview stage being 9 told about key suppliers, including Fujitsu. On joining 10 [Post Office Limited], I learned more detail about 11 Fujitsu building Horizon and that the contract had been 12 in place since the 1990s. I understood Horizon to be 13 the point of sale system at the Post Office counters 14 (SPMs, Crowns and Multiples) which would be used to 15 process and record all transactions performed within 16 a branch. I cannot recall any of the specific details, 17 but during my first few weeks at [Post Office Limited] 18 it is likely that I would have been given a walkthrough 19 of Horizon and it is possible that some high-level 20 architectural presentations regarding Horizon were 21 delivered to me. Beyond this, the only formal training 22 on Horizon I recall was a specific type of training 23 which was limited training on Horizon and more 24 specifically the Post & Go machines." 25 At the end of this paragraph you say: 8 1 "I would have had a high-level awareness about how 2 the system was architected, however as Head of IT/[Chief 3 Information Officer] I was neither a technical nor 4 a functional expert in Horizon." 5 Who was it who briefed you about the history of the 6 Horizon system when you joined the Post Office? 7 A. So I believe it would have been Head of Architecture at 8 the time, was David Gray. 9 Q. Who was it who you the walkthrough of Horizon? 10 A. It's likely to have been him, although I can't recall 11 any specifics, I'm sorry. 12 Q. You say at the end of the paragraph you were neither 13 a technical nor a functional expert in Horizon but, as 14 a former programmer with your background in numerous IT 15 roles, would you agree in general terms that you that 16 the relevant expertise to understand technical issues 17 which might and did arise from the operation of the 18 Horizon system? 19 A. At a level, yes, but deep, deep technical knowledge, 20 I would not have had that. 21 Q. In general terms, do you think that the IT function 22 within the Post Office was adequately resourced with 23 staff with appropriate expertise? 24 A. When I started, no. 25 Q. Can you help with why you say no? 9 1 A. It was quite a small operation and they were heavily 2 dependent upon Royal Mail at the time. 3 Q. Did that change? 4 A. It did change over time. It started through the 5 transformation, that was one of the key tenets, to build 6 the capability within that team. 7 Q. What were the implications of the IT function not being 8 adequately resourced with staff with appropriate 9 expertise? 10 A. So the IT function when I joined was very much -- 11 I would describe as a change function. So they dealt 12 mainly with change activity and, again, when I started, 13 the operational management of Fujitsu in particular, and 14 the links back into Royal Mail, sat within another part 15 of Mike Young's area, which was under Andy McLean. 16 Q. You deal with where the responsibility for the 17 day-to-day operational service management of Horizon and 18 the management of the contractual relationship with 19 Horizon lay at paragraph 8 of your statement. Could we 20 go to that, please. It's page 4 and you say here: 21 "Initially, during my tenure as Head of IT and 22 Change the day-to-day operational service management of 23 Horizon and the management of the contractual 24 relationship with Fujitsu was the responsibility of the 25 Managed Services team. Andy McLean ..." 10 1 McLean? 2 A. McLean. 3 Q. "... led this team and reported into the [Chief 4 Operating Officer] Mike Young. Managed Services at this 5 time was also responsible for the management and 6 oversight of the outsourced business activities and 7 relationships (eg Bank of Ireland/HP/Telephony). As 8 Head of IT and Change, insofar as Horizon was concerned, 9 I had responsibility for any IT change activity 10 (ie introduction of the Post & Go machines). If there 11 were any significant incidents (ie a P1 or P2 as I refer 12 to below at paragraph 18) the IT Team would be involved 13 to support any investigation into the incidents." 14 You say you: 15 "... raised with Mike Young that the responsibility 16 for the operational management and contractual 17 relationship management of the Horizon contact was in 18 the wrong part of [Post Office Limited] and should have 19 been under IT. As I have set out above, if there was 20 a significant incident involving Horizon, the Managed 21 Services team, supported by the separate IT Team, would 22 work together to investigate. The issue with this was 23 that the IT Team did not have full oversight of Horizon 24 (the contractual relationship with Fujitsu and 25 day-to-day management)." 11 1 Pausing there, what were the potential repercussions 2 of the IT function not having full oversight of Horizon? 3 A. So coming from Northern Rock, where I had full oversight 4 of the operational side, as well as change, this was 5 very different and, certainly, from my perspective, 6 I didn't have a full view of the whole IT landscape and 7 I didn't feel at the time that there was sufficient 8 oversight in terms of looking at that particular 9 contract itself. 10 Q. Were there any specific incidents which led to you 11 forming this view? 12 A. I think we'll probably come to this but certainly the 13 audits. 14 Q. What aspects of the audits? 15 A. 1 -- so these are the E&Y audits. The first part, 16 nobody had taken ownership for the audits, which was -- 17 I suppose that's the main point: nobody had actually 18 taken ownership of the audits. 19 Q. You go on: 20 "This changed when the Head of Managed Services left 21 in [Quarter 3/Quarter 4] 2011. From that point on, as 22 Head of IT and Change, I took responsibility for Service 23 Management, which included Horizon (the contractual 24 relationship with Fujitsu and day-to-day management)." 25 So by the third or fourth quarter of 2011, you had 12 1 responsibility for Service Management and that included 2 the day-to-day management and the contractual 3 relationship management; is that right? 4 A. That's correct. 5 Q. Prior to this, you had responsibility only for IT change 6 activity and providing support, if there were 7 significant incidents, graded as P1 or P2, which 8 required investigation. You define the P1 and P2 9 gradings at paragraph 18 of your statement: P1s you say 10 were a complete Horizon network outage; and P2s were 11 technical issues affecting a significant number of 12 branches? 13 A. Yes, that's correct. 14 Q. Is that right? 15 A. Yes. 16 Q. Looking, please, to paragraph 19 of the statement, 17 towards the bottom of the page, you describe here the 18 process for dealing with technical issues relating to 19 Horizon. You say this: 20 "Prior to my taking responsibility for Service 21 Management in [Quarter 3/Quarter 4] 2011, it was the 22 responsibilities of the Managed Services team to inform 23 me of these issues and engage with the IT Team. In some 24 cases, these cases these issues would be escalated to 25 the Executive. An incident review would then be carried 13 1 out by Fujitsu, who would provide a written response to 2 [Post Office Limited]. Any significant issues would be 3 discussed at the operational and executive supplier 4 reviews with Fujitsu. I understood that operational 5 reviews took place between Fujitsu and Service 6 Management every week. I was not involved in these 7 meetings. It is my understanding that executive reviews 8 were not taking place prior to me taking responsibility 9 for Service Management. Once I had taken 10 responsibility, I attended executive meetings either 11 monthly or bimonthly depending on the need with my 12 senior team, a Fujitsu Account Executive, sales 13 Executive and Service Executive." 14 You say that: 15 "... David Hulbert or the Duty Manager would 16 communicate P1s and P2s to all key stakeholders across 17 the business, keeping them updated [and you would 18 assist] in communicating P1s and P2s at executive level, 19 often by text message, telephone call, or in person." 20 Should the Chair understand from this paragraph that 21 you did not at any point, when you were Head of IT and 22 Change, attend the weekly operational Service Management 23 review meetings between Fujitsu and the Post Office? 24 A. That's correct, I didn't. 25 Q. That's both before and after taking on responsibility 14 1 for Service Management? 2 A. Yes, that's correct. 3 Q. Given your role within the business as Head of IT, do 4 you think you ought to have attended at least some of 5 those meetings, in order to understand the detail of the 6 operation of Horizon, including issues which might be 7 negatively affecting subpostmasters? 8 A. Typically, as Head of IT or CIO, you would not attend 9 the weekly meetings and that would be largely because 10 the executive meetings were there if there was anything 11 in particular that would need to be escalated or even 12 escalated outside of those meetings. 13 Q. As challenges to the integrity of the Horizon system 14 came into greater focus, did you consider attending 15 these meetings personally? 16 A. I didn't, because my priority -- this sounds awful -- my 17 priorities were very much about separation and I had to 18 trust my team, who were the experts, to escalate 19 anything to me. 20 Q. Were you personally involved in any investigation into 21 significant incidents? 22 A. I wouldn't say "investigate". I would be -- I would 23 receive incident reviews and, out of those incident 24 reviews there would certainly -- and I can't recall 25 specifics but there would certainly be detailed 15 1 discussions about those incidents themselves and, 2 certainly, the resolution of those incidents. 3 Q. Did anyone from the Post Office IT Team have any direct 4 involvement in the investigation of significant 5 incidents? 6 A. The Service Management Team would have done. 7 Q. What part would they play in investigations? 8 A. So they would work very closely with Fujitsu on the 9 incidents themselves and, in particular, to understand 10 the detail. I think also -- and again, this is just 11 from memory -- typically, you would get the architects, 12 the Chief Architect involved in that as well, so that 13 they could understand the low-level detail. 14 Q. Going, please, to page 7 of the statement and 15 paragraph 14, towards the bottom of the page, you say: 16 "Around the time I joined [Post Office Limited] in 17 April 2010, I recall that the second iteration of 18 Horizon (HNG-X) was in the process of being rolled out. 19 I understood that the changes were primarily as a result 20 of a cost reduction exercise, a refresh of some of the 21 hardware, and application changes to support 22 [subpostmasters]." 23 Who was it who explained to you the reasons behind 24 the change to Horizon Online? 25 A. I believe that would have been Mike Young and, 16 1 potentially, as I've said previously, the Chief 2 Architect, which was David Gray at the time. 3 Q. You go on: 4 "I later understood that there was a level of 5 resilience removed as part of the HNG-X rollout. 6 Previously branches could continue to operate if the 7 branch was unable to connect to the data centre, however 8 HNG-X required the branches to be connected to the data 9 centre to be operational. Coming from a banking 10 background (where branches could continue to transact if 11 they lost connectivity to the [database]) I had concerns 12 about this from an operational resilience perspective 13 (ie customers could not be provided with services if 14 branches lost connectivity)." 15 You say: 16 "This issues was addressed in papers to the Board 17 ..." 18 Those two documents you reference there are from 19 2012, by which time you were the interim Chief Operating 20 Officer; is that right? 21 A. That's right. 22 Q. Had the concern about operational resilience developed 23 prior to taking up that role, in other words when you 24 were still Head of IT? 25 A. It had and, at the time, I'd actually raised it with 17 1 Mike Young. 2 Q. Was that before or after you took on responsibility for 3 Horizon system day-to-day operation management? 4 A. I can't recall specifically, I'm sorry. 5 Q. Did you consider at the time, when you became concerned 6 about operational resilience, whether this feature of 7 Horizon Online, that is branch inability to transact if 8 they lost connectivity to the data centre, had any 9 implications for the accuracy of the branch transactions 10 recorded by the system? 11 A. No, I didn't. 12 Q. Do you think you should have considered that? 13 A. The way that the technology worked -- and if a branch 14 couldn't connect to the data centre because of 15 a material outage, they couldn't transact. 16 Q. Moving then to your executive roles, the interim Chief 17 Operating Officer role and then the Chief Information 18 Officer role, accompanied in 2015 by the Operations 19 Director role, what did you understand your 20 accountabilities to the Chief Executive Officer to be? 21 A. My accountabilities to the Chief Executive Officer? So 22 I was responsible for -- I suppose there was key things 23 that I was responsible for: delivering separation, 24 delivering transformation and the IT service. 25 Q. Did you recognise at the time that identifying, 18 1 analysing and managing risk was a fundamental part of 2 your executive responsibilities? 3 A. Sorry, yes, yes. 4 Q. Would you accept that, in order to discharge your 5 responsibilities in relation to risk, as an executive, 6 you needed to be proactive and curious about possible 7 risk areas? 8 A. Yes. 9 Q. Where you identified a risk in carrying out your 10 executive roles, what were the mechanisms in place for 11 you to raise that risk with the Chief Executive Officer? 12 A. So my reporting line was typically through another 13 executive, not directly to the Chief Executive. So if 14 there were any risks I would raise that with my line 15 manager, who changed over time, so that that could get 16 raised through to the Chief Executive. 17 Q. Do you consider that the culture at the Post Office was 18 supportive of executives reporting concerns about risk 19 to the Chief Executive Officer? 20 A. I think it was. I think that, probably latterly, 21 I would say that there was very much -- there was 22 a focus on risk. I think when I joined, I don't believe 23 there was because I asked for a risk register when 24 I joined and I couldn't -- there wasn't one for IT, 25 which had to be built. 19 1 Q. When you took on the role as Chief Information Officer, 2 you became the executive accountable for the contractual 3 relationship with Fujitsu in respect of Horizon; is that 4 right? 5 A. Yes, that's correct. 6 Q. Which you say at paragraph 9 of your statement included 7 overall oversight of any change activity and provision 8 of operational service from Fujitsu. 9 A. Yes. 10 Q. Do you think your colleagues at executive level relied 11 upon your IT expertise to assist in their own response 12 to issues involving the Horizon system? 13 A. I would expect so but also my team as well. 14 Q. You address discussions about the future use of Horizon 15 at the Post Office at paragraph 66 of your statement. 16 Could we have that on screen, please, it's page 32. 17 About halfway down the page, you say: 18 "I took a lead role in any discussions regarding the 19 future use of Horizon at [Post Office Limited] and 20 therefore have a clear recollection about this topic. 21 These discussions took place throughout my tenure and it 22 was a constantly evolving process. As set out above at 23 paragraph 7 I was accountable for [Post Office 24 Limited's] IT strategy post-separation with approval at 25 executive and Board level. I would have taken in views 20 1 from all key stakeholders across the business about the 2 IT strategy (including the future use of Horizon) and 3 would have ensured it aligned with [Post Office 4 Limited's] business strategy. From early on in my 5 tenure, it was clear that the Legal Team had concerns 6 about the Fujitsu contract as it was originally formed 7 in the 1990s and had never been out to public tender. 8 It was therefore difficult to assess its value for 9 money, particularly from a public purse perspective. 10 I also recall concerns from other business stakeholders 11 (ie Marketing and Retail) about how user-friendly 12 Horizon was and the time it took to change when 13 introducing business changes. In addition, technology 14 had moved on significantly since Horizon was introduced. 15 These concerns were continually raised and discussed 16 throughout my tenure." 17 Did you consider subpostmasters to be stakeholders 18 when you took up your Head of IT and Change role? 19 A. Yes. 20 Q. How did you obtain their views on the future use of 21 Horizon? 22 A. I can't recall specifically. I would think that -- 23 again, I can't recall specifically. I don't want to 24 guess. 25 Q. Well, can you recall at all how their views came to you? 21 1 A. So I know I did take time to visit some of the branches 2 and I think, especially when we had gone into the later 3 strategy, looking at the replacement of Horizon, I can 4 remember -- I've got a vague memory of pulling together 5 some forum to take in input from the stakeholders, 6 subpostmasters, but I'm really struggling to remember. 7 Q. Turning, please, to paragraph 72 of the statement, 8 that's page 36, you say: 9 "Any reviews of Horizon with regards to security and 10 stability that had taken place over the previous years 11 would have fed into the procurements and were 12 considered." 13 With this in mind, I'd like to look, please, at the 14 first review relating to the Horizon system, on which 15 you were sighted when you took up the Head of IT and 16 Change role, and that document is the Rod Ismay report. 17 You say at paragraph 16 of your statement that you 18 received a copy of this, due to your role as Head of IT, 19 shortly after you started with the Post Office and you 20 were, in fact, copied in to Mr Ismay's report on 21 2 August 2010; that's right, isn't it? 22 A. Yes. 23 Q. You say it was around this time that you first 24 understood that there were challenges to the integrity 25 of Horizon? 22 1 A. Yes. 2 Q. Could we have the Ismay Report on screen, please. The 3 reference is POL00026572. We can see here the title 4 "Horizon -- Response to Challenges Regarding Systems 5 Integrity", the date is 2 August 2010. It was sent by 6 Mr Ismay, who was Head of Product and Branch Accounting 7 at the time. Did you understand at the time you 8 received this report that Product and Branch Accounting 9 were involved in recovering apparent shortfalls in 10 accounts from subpostmasters. 11 A. I didn't appreciate that at the time. It was quite 12 early-on in my tenure at the Post Office. 13 Q. Looking at the "To" list, it's to Dave Smith, Managing 14 Director; Mike Moores, Finance Director; Mike Young, 15 Chief Technical and Services Officer. You are the third 16 on the copy list, as Head of IT. Did you read the 17 report in full when it was sent to you? 18 A. I believe I did. 19 Q. The introduction reads as follows: 20 "Post Office Limited has, over the years, had to 21 dismiss and product a number of subpostmasters and Crown 22 staff, following financial losses in branches. A small 23 number of these have made counter claims that they were 24 not guilty of the charges made but that the Horizon 25 system was faulty. 23 1 "Various lobby groups have been set up by former 2 subpostmasters and these have at times received national 3 media coverage and, in some cases, have been taken up by 4 local MPs. Most recently, Channel 4 has proposed a news 5 article about this area. 6 "This paper has been compiled as an objective, 7 internal review of [Post Office Limited's] processes and 8 controls around branch accounting. It includes 9 an overview of: 10 "[Post Office Limited's] control environment and 11 [Post Office Limited's] response to accounting errors 12 "IT systems -- Horizon versus Horizon Online and 13 resolution of known issues 14 "Third party perspectives -- court judgments, media 15 and audit [and] 16 "Statistics on branch accounting issues, suspensions 17 and prosecutions." 18 Pausing there, at the time, did it strike you as odd 19 that this review, done by someone from within the Post 20 Office, the Head of Product and Branch Accounting, was 21 being described as "objective"? 22 A. I can't remember what I thought at the time. 23 Q. What was your understanding at the time of why Mr Ismay 24 was preparing this report, rather than a Post Office 25 employee with IT expertise? 24 1 A. I don't know the answer to that, I'm sorry. I can only 2 guess and assume that it was because Rod had a huge 3 amount of experience across the business and understood 4 the controls that sat around the system. I also -- and 5 again, I'm trying to remember and I can't remember 6 because I wasn't involved in this part, but I believe -- 7 not believe, I think -- some of the IT architects might 8 have been included in this, to provide input to it. 9 Q. What did you understand to be the reason for this report 10 having been produced? 11 A. I didn't know the reason why it was produced. 12 Q. Before we go to the Executive Summary of the report 13 could we look, please, to page 19 of this document. 14 Under 4(c), "Independent Review and Audit Angles", we 15 have this: 16 "[Post Office Limited] has actively considered the 17 merits of an independent review. This has been purely 18 from the perspective that we believe in Horizon but that 19 a review could help give others the same confidence that 20 we have. 21 "Our decision between IT, Legal, P&BA, Security and 22 Press Office has continued to be that no matter what 23 opinions we obtain, people will still ask 'what if' and 24 the defence will always ask questions that require 25 answers beyond the report. Further such a report would 25 1 only have merit as at the date of creation and would 2 have to be updated at the point at which Horizon or the 3 numerous component platforms were upgraded." 4 You had, by this point, been Head of IT for around 5 four months, having taken up the role in April. Were 6 you the IT representative who contributed to the 7 decision not to commission an independent review? 8 A. No, I wasn't. 9 Q. Do you know who was? 10 A. I don't know who was. 11 Q. Going over the page, please, first paragraph here reads: 12 "It is also important to be crystal clear about any 13 review if one were commissioned -- any investigation 14 would need to be disclosed in court. Although we would 15 be doing the review to comfort others, any perception 16 that [Post Office Limited] doubts its own systems would 17 mean that all criminal prosecutions would have to be 18 stayed. It would also beg a question for the Court of 19 Appeal over past prosecutions and imprisonments." 20 Did you read this part of the report when you 21 received it? 22 A. I can't recall if I did. 23 Q. Do you recall having any concern about the description 24 here that the investigation would need to be disclosed 25 in court and a worry about that? 26 1 A. I think at this point I didn't really understand how 2 Post Office was prosecuting subpostmasters because 3 I just -- I just didn't have line of sight of this, and 4 I can't remember reading this, this detail, at the time. 5 Q. Going back then, please, to page 1 of the document to 6 the "Executive Summary". The first three paragraphs say 7 this: 8 "The allegations to which we are responding follow 9 on from cases where thousands of pounds were missing at 10 audit. We remain satisfied that this money was missing 11 due to theft in the branch -- we do not believe the 12 account balances against which the audits were conducted 13 were corrupt. 14 "[Post Office Limited] has extensive controls 15 spanning systems, processes, training and support. 16 Horizon is robust, but like any system depends on the 17 quality of entries by the users. Horizon Online builds 18 on this and brings benefits to running costs and change 19 management. It is not being done because of any doubt 20 about the integrity of Horizon. 21 "The integrity of Horizon is founded on its tamper 22 proof logs, its real time back ups and the absence of 23 'backdoors' so that all data entry or acceptance is at 24 branch level and is tagged against the log on ID of the 25 user. This means that ownership of the accounting is 27 1 truly at branch level." 2 Then over the page, please, second paragraph down: 3 "Accounting errors do happen through user mistakes, 4 but these can be explained and resolved case by case. 5 Systems issues have also arisen but again [Post Office 6 Limited] has been able to explain them and rectify them. 7 Whilst they have affected the availability and 8 functionality of the system, with consequent impacts on 9 customers and clients, they do not bring the integrity 10 of the system into question." 11 Then: 12 "When [Post Office Limited] takes a subpostmaster to 13 court we have strong processes for the compilation of 14 evidence, compassionate factors are borne in mind and we 15 have a high success rate. This does depend on ensuring 16 that the courts focus on the facts of transaction logs 17 and not on speculation about the 'what ifs'." 18 Would you agree that it is quite clear from both the 19 introduction to this report and the last paragraph that 20 I've just read out from the executive summary that 21 subpostmasters were being prosecuted and dismissed in 22 reliance on Horizon data, setting aside for a second the 23 question of who was doing the prosecuting? 24 A. Yes, that's how it reads. 25 Q. You say at paragraph 31 of your statement that you 28 1 understood from the Ismay Report that Horizon data was 2 being used as part of the supporting evidence in 3 prosecutions and the importance of the integrity of the 4 data; is that right? 5 A. Yes. 6 Q. But you say you do not recall appreciating that Post 7 Office could prosecute individuals itself without 8 referral to external authorities, and you say you didn't 9 realise that until around the time of the Second Sight 10 review. Looking at that introduction and the 11 penultimate paragraph here, the one I've just read out, 12 on the executive summary, on the face of the document, 13 wasn't it quite clear that, not only were subpostmasters 14 being prosecuted in reliance on Horizon data, they were 15 being prosecuted by the Post Office? 16 A. At the time when I've read -- so I don't recall thinking 17 that Post Office prosecuted subpostmasters at that time. 18 It was really not until the time of the Second Sight 19 Report that I really started to understand and 20 appreciate it because I just wasn't close enough to that 21 at this time. 22 Q. Looking, please, to some of the detail around systems 23 issues which were raised in Mr Ismay's report, it's 24 page 3 of the document, please. Under 1(a) "Systems", 25 the second paragraph in the box says: 29 1 "Failures in systems and file transfer do happen, 2 but [Post Office Limited] has controls to detect these. 3 The frequency of file transfer failures has been 4 unacceptably high recently and is a top priority for 5 IT." 6 What did you understand by systems and file transfer 7 failures at the time? 8 A. I wouldn't have understood anything about that at the 9 time because that's an operational issue and that sat 10 within a separate line, which was Andy McLean. 11 Q. That was Managed Services, was it? 12 A. That was Managed Services. 13 Q. So were you not aware that the frequency of file 14 transfer failures was a top priority for IT, that is 15 your team, at the time? 16 A. I wouldn't have been and the likelihood is, I think it 17 would have all been within the operational side and it 18 says IT but I don't recall anything to do with this. 19 Q. Shouldn't someone have told you that this was a top 20 priority for IT, the frequency of file transfer 21 failures? 22 A. If it was -- so if someone in my team was dealing with 23 it, yes. But that looks as if it's an operational 24 issue. 25 Q. So you read this report. What did you think when you 30 1 saw that this was a top priority for IT? 2 A. I really don't recall specifically reading this point. 3 Q. Going, please, to page 6, under the second bullet point 4 there is a heading "IT systems interventions and 5 response to outages/disconnections", and the bullet 6 point under that reads: 7 "Incomplete transactions -- systems could fail or 8 lines could be disconnected during online banking 9 transactions. This could mean that customer money has 10 changed hands without the system being update or vice 11 versa. IT controls would detect these outages and raise 12 recovery alerts to the branch such that the branch can 13 check and update the accounts if needed. This has been 14 a more frequent issue recently with 'screen freezes' and 15 'POCA outages' but recovery instructions have been 16 issued to branches and enable them to deal with any 17 issues." 18 Given that this report was being produced in the 19 context of challenges to Horizon integrity, raised in 20 the context of prosecutions of subpostmasters and those 21 prosecutions were said to rely on transaction logs, did 22 this paragraph in the report concern you at all? 23 A. I don't recall reading this in detail. Sorry, I just 24 don't recall what action I did or didn't take out of 25 this report. 31 1 Q. Was your team asked by Mr Ismay to comment on the impact 2 of the systems issues referred to in the report, on the 3 integrity of the data being produced by the system? 4 A. If I recall correctly, David Gray, who was the Chief 5 Architect, he worked closely with Rod Ismay on this 6 report. 7 Q. Going, please, to page 17 of this document, the section 8 on "Third Party Comment". Under 4(a) "Court Decisions", 9 the first two paragraphs read as follows: 10 "There have been cases, when taken to court by [Post 11 Office Limited], where the defence has claimed that the 12 accounting system Horizon was at fault and that there 13 were incidents such as 'ghost transactions' or 14 'electrical supply issues' which have corrupted the 15 Horizon records. 16 "With 2 notable exceptions, [Post Office Limited] 17 has been able to rebut these assertions by ensuring 18 a focus on the facts of the Horizon transaction logs and 19 a request for the defence to be specific about which 20 transactions they consider to be 'ghost' and why." 21 One of the notable exceptions is addressed about 22 halfway down this page, point 1, "Cleveleys, (2001)". 23 It explained: 24 "... subpostmistress dismissed in 2001 soon after 25 Horizon was introduced. The defence produced a report 32 1 which showed how Horizon 'could' have caused an error 2 and [Post Office Limited] did not have the audit 3 transaction logs to refute the claim." 4 Do you recall reading about this reference to 5 a report which showed how Horizon could have caused 6 an error? 7 A. I don't. 8 Q. That should have worried you, shouldn't it, as Head of 9 IT, that there was a report out there saying that 10 Horizon could have caused an error? 11 A. I think if I recall correctly, at the time of this 12 report, I'm sure I would have had some discussions with 13 the Chief Architect and a lot of these issues were seen 14 as Legacy issues to do with old Horizon. At the time, 15 I just can't -- I'm really struggling to recall this 16 report at the start of -- what, three months after 17 I joined. I'm really struggling to remember this in 18 detail. Again, I'd come in just very much to focus on 19 separation and some of these issues in here were 20 operational issues. 21 Q. You've explained how, looking forwards, this would have 22 been seen as a Legacy Horizon issue but, looking 23 backwards for a moment in the context of a report 24 raising challenges to Horizon integrity, did you 25 consider the implications for those who had been 33 1 prosecuted based on Horizon Legacy data? 2 A. At the time, I really didn't understand. I mean, 3 obviously now, you'd look at it in a different light 4 altogether but, at the time, I didn't really appreciate 5 the legal process and, from a legal perspective, that 6 wouldn't be for me to comment. 7 Q. Going back, please, to the executive summary, page 2, 8 the second paragraph down, which we've already read out. 9 The summary in that second paragraph relating to systems 10 issues that they have arisen but, again, Post Office 11 Limited has been able to explain them and rectify them, 12 there's a very short conclusion: 13 "Whilst they have affected the availability and 14 functionality of the system with consequent impacts on 15 customers and clients, they do not bring the integrity 16 of the system into question." 17 You say in your statement that you took Mr Ismay's 18 report at face value but, having read the report, given 19 your knowledge and background in IT, were you not 20 concerned to better understand Mr Ismay's logic and 21 conclusion? 22 A. So I can't comment for what Mr Ismay has said but, from 23 an IT perspective, if there is an issue or a fault, the 24 important points are always to understand what the issue 25 is, rectify the issue, and that would maintain in my 34 1 mind the integrity of the system. So, as long as you 2 know what it is, you know how to resolve it and you drew 3 the appropriate post-incident reviews and you've got 4 full sight of all of the data and the facts, that should 5 retain that. 6 Q. What questions did you ask and of whom when you read the 7 report? 8 A. I really can't remember. I'm sorry. 9 Q. Did you consider the processes which were in place to 10 ensure that Product and Branch Accounting, Contract 11 Managers and those involved in criminal investigations 12 and prosecutions, were kept informed about any systems 13 issues which had the potential to impact on transactions 14 data? 15 A. So I wouldn't be able to comment at that time because 16 communication would have been through Service 17 Management. 18 Q. When you were Head of IT, was there a central repository 19 within the Post Office for information about P1 and P2 20 incidents, which could be accessed by other departments 21 and teams? 22 A. There was a process in place called duty manager, which 23 basically would inform all key stakeholders across the 24 business. 25 Q. Did anyone tell you, as Head of IT, or later in your 35 1 executive roles, that the Post Office was bound as 2 a prosecutor to ensure the recording of information of 3 relevance to its prosecutions? 4 A. I can't recall specifically. 5 Q. Did you have any concept, when you were in any of your 6 roles at the Post Office, that it might be important for 7 the Post Office to record information about IT issues 8 which might affect data upon which it relied to 9 prosecute and take other action? 10 A. So, from an IT perspective, we would -- it's business as 11 usual to maintain information about faults and issues 12 and resolution. 13 Q. Were there established channels through which 14 information might be requested about technical Horizon 15 issues by Post Office lawyers, or was this done on 16 an ad hoc basis? 17 A. I'm not sure. Is this -- sorry, just to clarify, is 18 this from Fujitsu or is that just from internally within 19 the IT function? 20 Q. Well, taking it in general terms, and being -- well, 21 being specific, lawyers involved in prosecutions, so, 22 initially, Royal Mail Group Legal lawyers and later Post 23 Office lawyers, in terms of information, was there an 24 established way for them to obtain that information -- 25 A. I don't -- 36 1 Q. -- from IT about technical Horizon issues? 2 A. The only thing I was aware of -- and this came very much 3 later, once I took over the contract -- was a process to 4 get data between the lawyers and I think Fujitsu. In 5 terms of faults and issues, I don't recall anything. 6 SIR WYN WILLIAMS: Can I just ask, Ms Sewell, we've 7 obviously heard a good deal of evidence about the 8 Fujitsu processes for dealing with -- I'll just use the 9 word "defects" -- we've heard about PEAKs and KELs, 10 et cetera. Did the Post Office always go to Fujitsu -- 11 in your experience, obviously you can only speak for the 12 time you were there -- but if there was something that 13 occurred with the IT system, was it always "Go to 14 Fujitsu to find the answer", or did you have your own 15 processes for finding the answer, either first, shall we 16 say, or -- well, just never mind about first, did you 17 have your own processes for looking at problems and 18 trying to solve them? 19 A. So purely from an IT perspective, because Fujitsu 20 effectively ran the system and they had the IPR, 21 effectively, we would always look to go to Fujitsu. 22 SIR WYN WILLIAMS: Right. 23 A. The team would work together because you would 24 understand what the business impact was, so what's the 25 business impact, to be able to investigate the cause. 37 1 But the cause would have to be determined by Fujitsu. 2 SIR WYN WILLIAMS: All right. So how would you, the Post 3 Office Limited, ensure that relevant documentation about 4 a particular problem which was generated by the Post 5 Office, even if it was only to ask Fujitsu to help, how 6 would you ensure that that documentation would be 7 retained and kept for an appropriate period of time? 8 A. I think the only thing I would go back to is the 9 retention policy on documents. 10 SIR WYN WILLIAMS: Right. So there was a retention policy 11 throughout the period that you were there? 12 A. I can't speak for the whole period that I was there, 13 because, from what I remember, when -- and, again, 14 I think this is just a vague memory -- when I took over 15 Information Security, that was an area where we did look 16 at, was the retention policy. But I think typically it 17 was something like about seven years, if I -- and I've 18 seen that in some of the documents that I've been 19 provided. 20 SIR WYN WILLIAMS: Was it the IT Department itself which had 21 a retention policy or was it a policy that applied 22 throughout all departments of the business? 23 A. So, typically you would expect, in an organisation -- 24 and again, I'm just -- I'm trying to remember but, 25 typically, you would have that set -- the retention 38 1 policy wouldn't necessarily be set by IT. That would 2 typically be set by somebody like Information Security, 3 or the Data Protection Officer of the organisation, and 4 that could be within Royal Mail or Post Office. They 5 would set the policy and then the departments, including 6 IT, should adhere to that policy. 7 SIR WYN WILLIAMS: Sorry, Ms Price; I may have been 8 trespassing on some of your questions, but -- 9 MS PRICE: Not at all, sir. 10 SIR WYN WILLIAMS: -- I was just getting those thoughts out 11 at this time. 12 MS PRICE: We look ad earlier at paragraph 19 of your 13 statement, in which you said that P1s and P2s would be 14 communicated to all key stakeholders across the 15 business. Were the Investigators -- that is the 16 Security team, Investigators who were criminally 17 investigating subpostmasters and others -- were they 18 considered key stakeholders for those purposes? 19 A. I can't remember specifically but I do think Information 20 Security was included. 21 Q. Can you recall whether the relevant legal teams, that is 22 the lawyers involved in prosecutions and debt recover 23 recovery, were key stakeholders for this purpose, that 24 is the communication of P1s and P2s? 25 A. I can't recall who was on that list, but what I can say 39 1 if it was a P1 and if that was communicated to all the 2 execs, that would have included those as well. 3 Q. Having received Mr Ismay's report, do you think that 4 you, as Head of IT, should have raised the issue of 5 information flow within the Post Office between the 6 relevant teams and departments? 7 A. At -- and this is where it's difficult because, at that 8 time, that responsibility lay -- although it was under 9 Mike Young, it lay within Andy McLean's area. 10 Q. When you took up the role as Head of IT, did you ask 11 what documentation might be in the Post Office IT 12 Department's possession to assist with the role of 13 overseeing IT systems? 14 A. Yes, I did. 15 Q. What were you told? 16 A. I was given -- I don't believe I was given a lot of 17 documentation at the time. 18 Q. Were you given, for example, release notes? 19 A. No. 20 Q. Major incident reports? 21 A. So the first major incident reports that I would have 22 seen would have been whilst I was CIO. 23 Q. Did you have any sight of NBSC call records -- 24 A. No, not at all. 25 Q. -- or Service Management documents? 40 1 A. I would have seen a high-level Service Management so, in 2 terms of service availability but I think that would 3 have been -- so probably end of 2011/into 2012, once 4 I took some responsibility. 5 Q. Do you think that you should have asked to see more 6 documentation in relation to oversight of the IT system, 7 Horizon system? 8 A. So, when I wasn't responsible, I don't think so. But 9 when I was responsible, I would see documentation and 10 I would see executive summaries. In the role of CIO, 11 you wouldn't get into that level of detail, 12 unfortunately. 13 Q. I'd like to turn, please, to Post Office awareness of 14 relevant bugs, errors and defects in Horizon following 15 the Ismay Report, starting, please, with the receipts 16 and payments mismatch bug. Can we have on screen, 17 please, POL00294684. This is an email from Antonio 18 Jamasb on 15 November 2010. 19 Apologies, it relates to a proposed meeting on 20 15 November 2010 to discuss a proposal for receipts and 21 payments resolution. The first invited attendee listed 22 was David Hulbert, who was listed as a required 23 attendee. Was Mr Hulbert in your team at that time, 24 November 2010? I know he was later a direct report. 25 A. No, he wasn't. He reported to me some 12 months later. 41 1 Q. Also listed was Ian Trundell, was he in the Post Office 2 IT Department? 3 A. I think he may have been an architect. 4 Q. Did he report to you? 5 A. No, he didn't. 6 Q. The body of the email, if we can scroll down a little 7 please, contains a summary of the problem, explained in 8 the first three paragraphs. It says: 9 "The aim of the meeting is to discuss the working 10 group proposal: to resolve discrepancies generated by 11 branches following a specific process during the 12 completion of the trading statement. 13 "Service Delivery recently became aware of an issue 14 whereby if a certain process was followed during 15 completion of the trading statement any discrepancy the 16 branch was carrying, either positive or negative, would 17 'drop' from the Horizon system, but still show within 18 the Credence system. 19 "Few branches were aware of the issue, but it 20 creates questions around whether the Horizon system can 21 cause losses or gains. However it also highlights 22 positives in our management of the system, because once 23 the issue arose we were able to highlight it, quickly 24 investigated the problem and then ring-fence the issue 25 while ascertaining a fix to stop it recurring, but it 42 1 doesn't resolve the issue at branches that already have 2 the issue." 3 On the next page, some solutions are set out. We'll 4 come back to those in due course. Were you aware of 5 this meeting taking place at the time? 6 A. No. 7 Q. We have a note of the meeting, which took place to 8 discuss the issue. Can we have that on screen, please. 9 The reference is FUJ00082110. We do not see 10 Mr Hulbert's name on the list but we do see Ian 11 Trundell's name listed next to "IT", so it appears that 12 he was the representative for IT at this meeting; would 13 you agree? 14 A. Yes. 15 Q. Also present were representatives from Post Office 16 Service Delivery, Post Office Security, Post Office 17 Network, Post Office Finance, and various 18 representatives from Fujitsu. So it would appear that 19 the receipts and payments mismatch bug was known about 20 across these major relevant departments within the Post 21 Office at the time, would you agree? 22 A. Yes. 23 Q. Did Mr Trundell report the outcome of this meeting to 24 you at the time? 25 A. I don't recall him speaking to me about it. 43 1 Q. Were you sent this note of the meeting? 2 A. I don't believe so. 3 Q. I should be clear about that. Were you sent the note of 4 this meeting at the time, in 2010? 5 A. I don't believe that I was. 6 Q. Could we have on screen, please, POL00029611. You 7 appear to have been involved in the response to the 8 receipts and payments issue in March 2011. The email, 9 starting about halfway down the page, is from Will 10 Russell to you, copied to Andy McLean. 11 It appears from the sign-off at the bottom that 12 William Russell was a Commercial Adviser in the Post 13 Office Service Delivery Team, and it's dated 4 March 14 2011. The subject is "Receipts and payments issue", and 15 it says: 16 "Lesley 17 "Quite a lot of info here but I will outline what we 18 agreed on this issue. 19 "Word documents attached are the letters going out 20 to branches on Monday. They have been approved by Legal 21 and P&BA (Andy Winn) and SD (Tony J). 22 "I ran Mike G, Mike Y and Andy M through the detail 23 last week. We have agreed to write off the losses and 24 repay the gains via subpostmaster pay. We have 25 a document from Fujitsu on what happened (see pdf file). 44 1 This provides audit trail and shows what happened for 2 a branch, as well as events generated and logged by 3 Fujitsu, plus what the branch saw on their reports. 4 I am just awaiting clearance from network (Anita Turner) 5 re how to approach NBSC (propose to finalise that on 6 Monday for 62 branches affected as shown on Excel 7 sheet). 8 "Matt Hibbard was happy with the process and Fujitsu 9 document, as Rod was off. Andy Mac has taken action 10 from Mike Y to ensure we maintain closer links with 11 P&BA/Rod. Tony J ... is already working on issue 12 management and how P&BA raise issues with SD, and this 13 will help SD to formally raise and resolve them with 14 Fujitsu. 15 "Both Mikes were keen we use this as a positive, 16 eg old Horizon would not have picked this up, yet the 17 logs in Data Centre, and Event alerting meant we picked 18 this up, and can demonstrate through reports what 19 happened. We can generate reports for each branch if 20 challenged. 21 "We are writing to branches, and following up with 22 call from NBSC/P&BA with walkthrough of the detail as 23 required. We have commitment from Fujitsu to visit any 24 branches to run them through what happened with them. 25 We have had receipt and payments mismatches before, so 45 1 this is not something new to manage, albeit that this 2 issue was very complicated in how it was reported, and 3 evident to the branch." 4 Picking up, first of all, on that last sentence in 5 the penultimate paragraph, "We have had receipts and 6 payments mismatches before"; can you help with what this 7 is referring to? 8 A. I don't know, I'm sorry. 9 Q. Did you question at the time what it was being referred 10 to here, in terms of past receipts and payments 11 mismatches? 12 A. I can't recall at all. 13 Q. But it appears that this was not the first time that 14 this type of issue had arisen? 15 A. That's what it appears. 16 Q. This particular receipts and payments mismatch issue had 17 come up around three months after Mr Ismay's report and 18 you seem to have been involved in the response by March 19 2011, so seven months after Mr Ismay's report. Did this 20 issue cause you to question the conclusions reached by 21 Mr Ismay in his report at all? 22 A. I can't recall that it did, because -- I really don't 23 recall that it did because this was under -- this was 24 being managed separately, and Mike Young's referenced as 25 well, so it wouldn't have registered as a major issue to 46 1 me at the time. 2 Q. This particular issue had been resolved with the 3 affected branches? 4 A. Yes. 5 Q. But did you consider what the implications of this were 6 for other branches or past issues that might have arisen 7 where there may have been action taken against 8 a subpostmaster and others? 9 A. I can't recall if I did or didn't. 10 Q. Did you consider whether information relating to this 11 bug should be shared with those involved in dismissals, 12 contract terminations, prosecutions and debt recovery? 13 A. I wasn't close enough to understand what was happening 14 on that side of the business and I think this was 15 a major issue with the different responsibilities 16 between operational management and change. 17 Q. Did you consider at all whether this cast doubt on the 18 reliability of the Horizon transactions data being used 19 in support of action against subpostmasters and others? 20 A. I don't recall that I would have because it looked as 21 if, on the face of it, the problem had been solved. 22 Q. This was one of the bugs or defects referred to in the 23 Interim Second Sight Report, wasn't it? 24 A. Yes, it was. 25 Q. Could we have on screen, please, POL00029618. This is 47 1 an email chain from June 2013. 2 A. Mm-hm. 3 Q. In it, Ron Warmington is seeking clarification as to 4 whether anyone at Board level was aware of the receipts 5 and payments mismatch bug and, if so, who and when? 6 A. Yes. 7 Q. Your email is at the top. 8 A. Yeah. 9 Q. It's 25 June 2013 to Simon Baker and Alwen Lyons, and 10 you say this: 11 "Simon, I don't know if it went higher than Mike, 12 Andy Mc also managed the service at the time and if 13 I remember correctly Mark Burley was also involved. 14 "I can't say whether we said anything to the press. 15 "Other points -- our Board at the time would have 16 been Royal Mail as we didn't have an independent Board. 17 Paula would have been Network Director at the time with 18 Dave Smith as MD." 19 Who was the "Mike" who you're referring to here? 20 A. Mike Young. 21 Q. "Andy Mc", was that Andy McLean? 22 A. Yes, that's right. 23 Q. Mark Burley, what was his role in 2010 to '11? 24 A. He was heading up the rollout of HNG-X. 25 Q. When you were involved in the response to the receipts 48 1 and payments mismatch bug in March 2011, you were Head 2 of IT. Who did you report this issue up to? 3 A. The receipts and payments issue? 4 Q. In March 2011? 5 A. March 2011? I didn't report it up to Mike because Mike 6 was already aware of it, mike Young. So I reported to 7 Mike Young at the time. 8 Q. Did you report it to anyone else? 9 A. I wouldn't have done because it was -- it's -- the 10 reporting line for operational management and management 11 of faults was Andy McLean up to Mike. So Mike was well 12 aware of this fault. 13 Q. Can you help with your comment here about there not 14 being a Post Office Board at the time, presumably 15 meaning at the time the receipts and payments mismatch 16 bug came to light in 2010? 17 A. Yeah, because I think at that time it was prior to 18 separation. So we were still governed by Royal Mail at 19 that time and I wasn't aware that -- and I don't think 20 we had an independent Board. There was an Executive 21 Team and I think David Smith may have sat on the board 22 at Royal Mail. 23 Q. Can you help to any greater degree than you have with 24 your comments in this email with how high up the 25 knowledge of the receipts and payments mismatch bug went 49 1 prior to it being discussed in the context of Second 2 Sight's work in 2013? 3 A. I don't know. I gave as much information as I had at 4 the time. 5 Q. Given your knowledge from the Ismay Report that Horizon 6 data was being relied upon to dismiss and prosecute 7 individuals, when you first found out about the receipts 8 and payments mismatch bug or bugs, did you consider 9 discussing the potential wider implications of this with 10 Product and Branch Accounting? 11 A. I can't -- I can't recall if I did because I wasn't 12 actively involved in this particular fault at the time. 13 Q. Or anyone from Network? 14 A. I really wasn't involved in this fault at the time. 15 MS PRICE: Sir, I wonder if that might be a convenient 16 moment for the morning break. 17 SIR WYN WILLIAMS: Yes, by all means. So what time shall we 18 resume? 19 MS PRICE: I think ten minutes takes us to 11.15, please, 20 sir. 21 SIR WYN WILLIAMS: By my clock, because I want to ensure we 22 have a full ten minutes, it's 11.07. 23 MS PRICE: Very happy to come back at 11.20, sir. 24 SIR WYN WILLIAMS: All right, that's fine, thank you. 25 MS PRICE: Thank you. 50 1 (11.07 pm) 2 (A short break) 3 (11.20 am) 4 MS PRICE: Hello, sir. Can you still see and hear us? 5 SIR WYN WILLIAMS: Yes, indeed. 6 MS PRICE: Could we have on screen, please, POL00294852. 7 This is an email chain from September 2011. So at this 8 point, you were still in the Head of IT role. Starting, 9 please, with the first email in this chain, dated 10 28 September 2011, that's page 2 of this document, there 11 is an email from Gary Blackburn, just scrolling down, 12 please, who is IT and Change. So was that your team? 13 A. Yes. 14 Q. Scrolling up, please, this is to a number of recipients, 15 including you, Dave Hulbert and Alison Bolsover. The 16 subject is "Camelot -- Missing Data in POLSAP", can you 17 just help with what POLSAP was? 18 A. So the -- it was Post Office -- I don't remember the 19 technicalities of POLSAP but it was, in technical terms, 20 it was a SAP system. 21 Q. Mr Blackburn explains the issue in this way under "What 22 has happened": 23 "The root cause is still to be determined but P&BA 24 colleagues have identified that there is data missing 25 within POLSAP. The missing relates to multiple rems 51 1 undertaken on [a number of dates in September]. The 2 affected transactions are when the rem was for the same 3 product, same value and completed on the same day 4 (appears like a duplicate rem). The data is zero value 5 stock data, which is rem in/rem out products such as 6 Camelot scratchcards and MVL tax discs. 7 "In total we have 71 products that are classed as 8 zero value stock data." 9 The "Impact" is: 10 "Because the data is missing within POLSAP, P&BA 11 have understandably issued transaction corrections to 12 branches that appear to have not conformed to business 13 process. 14 "309 branches within branch trading group C have 15 received TCs inappropriately. 16 "90 of those branches have complained to P&BA and 17 explained that they will not be processing the TC." 18 Would you agree that Mr Blackburn appears to be 19 identifying a problem where branch transaction data went 20 missing? 21 A. I don't know whether it's branch transactional data. 22 Q. Can you help with what it is? 23 A. Because the branch transactional data would have been 24 held within Horizon, not POLSAP. So that was my 25 understanding. 52 1 Q. Looking down to the "Resolution": 2 "Fujitsu are presently working on the identification 3 of the missing data and are devising a plan to get that 4 data into POLSAP." 5 This seems to have involved Fujitsu. 6 A. Mm-hm. 7 Q. "At the moment the fix is not expected to be available 8 until the middle of next week ..." 9 It says at the end of this paragraph: 10 "It was decided by P&BA and myself that we would not 11 communicate this wider at this stage as we do not wish 12 to raise concerns about Horizon integrity." 13 Does that help at all with the context for this? 14 A. So I can't remember the issues specifically but Fujitsu 15 hosted POLSAP as well and there was obviously a concern 16 from Rod, as part of this, but when I saw this in the 17 pack, I really struggled to remember this particular 18 incident. 19 Q. Why would it be related to concerns about Horizon 20 integrity? 21 A. So I can only assume, you know, what Gary's written and 22 obviously from Rod, that -- because it's relating to 23 data. That's all I can assume. 24 Q. What did you think about the decision that this was not 25 going to be communicated more widely as they did not 53 1 wish to raise concerns about Horizon integrity? 2 A. So, as an IT person -- and I say this throughout my 3 career -- it is important to be transparent about issues 4 and I would always advocate that. There may be a point 5 which you want to understand an issue first before you 6 communicate, and I can only assume that's been the 7 discussion between -- because I think this was from 8 Gary, and it references P&BA, so I can only assume 9 that's Rod as well. 10 Q. Going back to page 1 of this document, please, and 11 scrolling down a little, please. We can see you 12 forwarding this on to Kevin Lenihan -- 13 A. Mm-hm. 14 Q. -- copied to Dave Hulbert and Rod Ismay on 29 September 15 2011. What was Mr Lenihan's role? 16 A. So Kevin worked within Service Management and he 17 reported directly through to Dave Hulbert. He was 18 located in Chesterfield so he was quite close to Rod 19 Ismay's area, so it would have been easy for him to pick 20 this up and go into a lot of detail with Rod to 21 understand what the issues were. 22 Q. You say this: 23 "Kevin 24 "I would like you to pick up a piece of work on 25 behalf of Rod and I -- Rod has concerns that we are 54 1 seeing a number of data issues and the perception is 2 that this is getting worse. Can you please work with 3 one of Rod's team to quantify/qualify what these issues 4 are -- I would like to understand if we have any 5 systemic issues." 6 What is your concern about this; is this relevant to 7 branch accounts or not? 8 A. I can't remember but if this -- and it obviously 9 reference transaction corrections, so there's obviously 10 a piece of work needed to be done to ensure that the 11 branch transactions were kept up to date and 12 appropriate. So my concern would have been "It looks 13 like a data issue, can we get to the bottom of it, 14 please, and understand what this is". 15 Q. It appears, doesn't it, on the description, as though it 16 is an issue, whatever the issue is -- 17 A. Mm-hm. 18 Q. -- which has affected branch accounts -- 19 A. Yes. 20 Q. -- because there are transaction corrections which have 21 been wrongly issued, which need to be reversed. What 22 was your concern about the systemic issues or potential 23 systemic issues? 24 A. And again, from an IT perspective, if there's a material 25 issue with data, you need to understand what that issue 55 1 is. So systemic, to me, is widespread. 2 Q. Did this make you question the integrity of Horizon at 3 all? 4 A. I can't remember, sorry. 5 Q. Could we have on screen, please, POL00142676. Starting 6 please towards the bottom of page 2 of this document, 7 an email from Adrian Baker to you, dated 3 January 2012, 8 and the subject is "Branch feedback". We can see from 9 top of the next page that Mr Baker was Head of Strategy 10 at the Post Office and his email to you reads: 11 "Lesley, 12 "First of all -- happy new year! 13 "Secondly, a quick but if of feedback/question from 14 my time in branch before Christmas. There seems to be 15 a slight glitch with the Quantity function, especially 16 when used with stamps. It seems quite random as to 17 whether the quantity selected follows the user into the 18 next screen when selling loose stamps. Sometimes it 19 does, sometimes not. On occasions the quantity clears 20 back to 1 but then when you select the stamp 21 denomination suddenly remembers the quantity. The 22 feedback from St Peters Street branch is that this is 23 the single most common cause of losses in their branch. 24 "Can you have one of your team investigate, please?" 25 Further up the page, please, you forward this on to 56 1 Dave Hulbert on 5 January 2012, asking one of the team 2 to take a look. Mr Baker was raising a glitch in the 3 quantity function which affecting branch accounts, so 4 causing losses, is how he's put it; did this cause you 5 any concern? 6 A. I don't recall this email. 7 Q. Looking at it now, do you connect this at all to 8 concerns or questions about Horizon integrity? 9 A. So it could potentially be or it could be a hardware 10 fault but it goes back to, if faults are investigated 11 and if they are dealt with, that retains the integrity 12 in the system. 13 Q. Could we have on screen, please, POL00096881. This is 14 an email chain from August 2012. It relates to apparent 15 shortfalls at a branch totalling £18,000, over 16 an 18-month period. It was a case which was raised with 17 you by Angela van den Bogerd. Starting, please, on 18 page 5 of this document, this is an email from -- if we 19 can just go back a page, please, to the bottom -- 20 Contract Admin Team, 2 August 2012, and it's to Anita 21 Bravata. Someone called Trudy, summarises the position 22 in this way: 23 "Hi Anita -- I rang the PM, Jane, at Semilong [post 24 office] this morning just as an engineer had arrived at 25 her branch. She explained that she has had an ongoing 57 1 problem with discrepancies at her branch for the last 2 18 months and you were aware of the situation. She said 3 yesterday on Position 3 there was less than £1,000 4 working cash. The clerk did a balance snapshot and it 5 was £170 over -- she immediately did a printout and it 6 was then showing as £700 under. So she knows there is 7 a fault on the Horizon system. I agreed I would ring 8 her back at 1.00 pm to see what the engineer had found 9 out. 10 "I have just rang Jane back and she was so happy she 11 said she could cry with relief. The engineer said there 12 is a definite fault on the line -- there was a bad noise 13 on the line and this was probably causing a 'loop' -- he 14 said it may be caused by her PayStation. He has changed 15 the faceplate and the ADCL cable and is hoping this 16 solves the problem. Horizon team will now keep an eye 17 on it and may ring her to tell her to disconnect her 18 PayStation and then send her a new one. 19 "She has always known that the TCs were not hers but 20 has always settled centrally -- a total of approximately 21 £18,000 over the last 18 months -- she has even had to 22 cash in her pension to pay these off and now is asking 23 for this money back. 24 "Can you advise how we go about seeing how much 25 money this lady is due back please." 58 1 Can you go back to page 3 of this document. The 2 email at the top of the page here from Angela van den 3 Bogerd is dated 3 August 2012, and this to Craig Tuthill 4 and Lin Norbury, and she says: 5 "Lin, 6 "I have not (to my knowledge) been made aware of 7 this branch previously and their ongoing claims that 8 discrepancies incurred were as a result of the Horizon 9 system. The content of the email chain below has the 10 potential to said hares running before we properly 11 understand what has gone on here and what the potential 12 consequences are. Therefore can I have as a matter of 13 urgency the background on this branch, including the 14 balancing records since the agent was appointed; TCs; 15 NBSC and Horizon helpline logs and all associated 16 correspondence. I will flag this to the JFSA Working 17 Group and in particular raise with Lesley Sewell in 18 relation to the Horizon system." 19 Then we can see, at the top of page 2, please, 20 Angela van den Bogerd forwarding this to you, saying 21 she's left a voicemail also, asking to discuss. Then 22 page 1, please, your email starting in the middle of the 23 page, that's also dated 3 August 2012, sent to Stephen 24 Long, copied to Angela van den Bogerd, and it says this: 25 "Stephen 59 1 "Can you help with this issue -- it is obviously 2 quite sensitive. 3 "The branch has had issues over a period of months 4 and the engineer has just found a fault on the line. We 5 would like a view on whether or not this type of fault 6 would cause an issue of this nature -- as you will see 7 from the email that this is to the tune of £18,000. 8 "Angela is leading the investigation from Post 9 Office ... 10 "I realise this is probably outside of the usual 11 process but there is a nervousness around this one and 12 the fact that the branch now believe the cause has been 13 found." 14 This is forwarded on, scrolling up, please, to 15 Gareth Jenkins by Stephen Long for a view. We can see 16 there he's being asked to take a look, the matter is 17 sensitive. He says: 18 "I have a very clear view on Lesley's question 19 regarding the possibility of a network fault causing 20 such discrepancies over such a long period; however, you 21 have far more knowledge and experience than me. What do 22 you think?" 23 Were you concerned about the situation which was 24 being brought to your attention, that is £18,000 of 25 apparent shortfalls being reported over 18 months? 60 1 A. Yes, and that's why I raised it with the Account 2 Executive. 3 Q. The subpostmaster in this case was convinced that the 4 apparent shortfalls were caused by the system but she 5 had cashed in her pension to settle centrally up to this 6 point. Did this give you any cause for concern in 7 relation to the fact that this subpostmaster had felt it 8 necessary to settle centrally for apparent shortfalls 9 which she was convinced were the fault of the system, 10 not her? 11 A. So yes, I would have been concerned about it. 12 Q. Did you raise that aspect with anyone? 13 A. I can't recall exactly what I did or didn't because 14 I have looked at this and other documents within the 15 pack, because I couldn't understand why I'd copied Andy 16 Garner and, unfortunately, I went off to have 17 an operation straight after this, two days later so ... 18 Q. Do you need to take a break? 19 A. No, I'm okay. I clearly feel so bad for the 20 subpostmaster. 21 SIR WYN WILLIAMS: Could you tell me who Stephen Long is? 22 A. So Stephen Long was the Account Executive at Fujitsu -- 23 SIR WYN WILLIAMS: Right, I see. It's not a name I've come 24 across, so he's Fujitsu? 25 A. Yes. So I took this very serious -- I can see I took 61 1 this seriously when I read the email in the pack and 2 I escalated it to my senior counterpart at Fujitsu to 3 examine what had gone on here. 4 SIR WYN WILLIAMS: Well, that was my next question. He had 5 the same kind of seniority at Fujitsu as you had at Post 6 Office, yes? 7 A. Yes, he did and my regret with this is I don't know what 8 happened out of it. 9 SIR WYN WILLIAMS: Yes, I follow that you have explained 10 that. But thank you for telling me who Mr Long was. 11 A. Thank you. 12 MS PRICE: Can we have on screen, please, POL00029641. 13 Starting, please, with page 4 of this document, towards 14 the bottom of the page, there is an email from Gareth 15 Jenkins to you dated 28 June 2013, and Mr Jenkins says: 16 "Lesley, 17 "The local suspense problem was first raised as 18 a call on the Horizon Helpdesk by NBSC at 4.51 pm on 19 Monday, 25 February 2013 ... 20 "Problem diagnosed by Thursday, 28 February and 21 a conference call held with [Post Office Limited] to 22 brief them as to the issue and its scope." 23 In your email reply above, dated 3 July 2013, you 24 ask for details of this call: 25 "... I'm interested in the detail and who raised 62 1 it." 2 Then follow some further emails before a timeline is 3 sent by Rodric Williams to you and Rod Ismay, so page 1, 4 please, about halfway down the page. This is copied to 5 Andrew Winn, Hugh Flemington and Simon Baker. We can 6 see from the timeline here, can't we, that the issue 7 first came to the attention of the Post Office, the 8 first bullet point here, specifically Post Office 9 Finance Service Centre, on 6 February 2012, at the close 10 of a branch trading period; would you agree? 11 A. Yes. 12 Q. The events which followed were these, so: 13 "The issue raised concerned the £9,799.88 14 discrepancy at the Willen branch. 15 "FSC might have proactively contacted [the 16 subpostmaster] given the size of the discrepancy. 17 "FSC investigated, saw that it looked wrong, and 18 brought the account back to balance (i3 £0) at no cost 19 to the [subpostmaster]. 20 "FSC would have monitored the Willen branch to see 21 what happened the following month. 22 "Over the next few weeks, as the rest of the branch 23 trading data for the same period was processed, the 24 other 13 branch anomalies were noted. 25 "Those other branches' accounts were brought to 63 1 balance, again at no cost to the subpostmaster. 2 "This was not perceived to be a significant issue 3 given the small number of branches affected and the 4 small sums involved." 5 Then: 6 "On 6 February 2013 [so a year later] the Willen 7 [subpostmaster] contacted [Post Office Limited] National 8 Business Support Centre to report the same discrepancy 9 in his branch trading as the previous year." 10 Over to the top of the next page: 11 "NBSC passed this on to Fujitsu between 6 and 12 8 February 2013. 13 "Fujitsu then notified FSC of the problem on 14 28 February 2013. 15 "Fujitsu resolved B14 on 25 April 2013." 16 So a full year later, we have this issue being 17 reported by the same subpostmaster to the NBSC. The 18 Post Office knew about the suspense account bug for 19 a full year before Fujitsu was informed about it; is 20 that right? 21 A. So they were -- Post Office were aware -- from what 22 I understand, the FSC were aware of a discrepancy at 23 that particular branch. It wasn't identified as a fault 24 until a year later. So they weren't aware that it was 25 a fault. 64 1 Q. So they were aware of the impact -- 2 A. Impact but not that it was a fault, until a year later. 3 It wasn't found until a year later. 4 Q. It appears that someone did not regard the issue as 5 significant, given the small number of branches 6 affected. Do you know who it was who made that 7 assessment? 8 A. I don't know who would have made that assessment. 9 Q. Okay. Is this a reflection of the P2 grading system at 10 the time that something was only graded a P2 -- that is 11 a significant incident -- if a significant number of 12 branches were affected, or would that not have been 13 being considered by FSC? 14 A. No, because -- the FSC would not determine whether it 15 was a P1 or a P2. That would come into IT for them to 16 understand what the issue was and what the impact was. 17 As I understand it, FSC had obviously dealt with this -- 18 dealt with Willen branch in -- forgive me, 2012, yeah? 19 And there was no issue found, so the discrepancy was 20 written off, as I understand it. 21 Once Willen branch came back a year later and there 22 was more detailed investigation, it was at that point 23 that we understood that there was a fault. I don't know 24 when IT was involved, at which point. I don't know 25 whether they were involved when the one branch raised 65 1 the issue but we were certainly involved, obviously, 2 when there was more branches. 3 Q. At the time, was there any guidance in place for the FSC 4 as to when they should refer something either to IT 5 within the Post Office or to Fujitsu? 6 A. I don't know the answer to that one, I'm sorry. 7 Q. Had you been made aware of the suspense account bug 8 before June 2013? 9 A. I was made aware of it once we understood it was 10 a fault, so that would have been in 2013. 11 Q. What was your reaction when you saw this timeline in 12 July 2013? 13 A. It wasn't good. However, I think if you've got -- if 14 there's one discrepancy in a big system, that's hard to 15 find if there was a fault. And it was obviously 16 investigated at the time and they couldn't find a fault. 17 I think the main concern for me would have been to 18 ensure that the branch was not disadvantaged, which they 19 weren't. 20 Q. Given that this had gone unidentified as a bug for 21 a year, did you have any concern that there might have 22 been branches affected that hadn't been identified? 23 A. The resolution, as I understood it, identified all 24 branches that were affected. 25 Q. That document can come down now. Thank you. 66 1 The third bug which was referenced in the Second 2 Sight Interim Report was the Falkirk bug. Do you recall 3 becoming aware of that in the summer of 2023 (sic)? 4 A. Only through the Second Sight Report. 5 Q. The draft briefing note, which was prepared for Paula 6 Vennells on the Second Sight review into Horizon, which 7 was dated 2 July 2013, is a document you refer to at 8 paragraph 18 of your statement, and that deals with this 9 bug, the Falkirk bug. Could we have that on screen, 10 please. The reference is POL00029627. 11 Page 5 of this document, please. Towards the bottom 12 of the page there is a heading "Other anomalies -- 13 'Falkirk'". We'll come back to the terminology of 14 anomalies in due course but, for now, focusing on the 15 information being provided in this draft briefing, it's 16 explained: 17 "We are also aware of a further anomaly in Horizon 18 which was been considered in both criminal and civil 19 Court proceedings the -- the 'Falkirk Anomaly'. 20 "The Falkirk Anomaly occurred when cash or stock was 21 transferred between stock units. It was resolved in 22 March 2006 and is therefore a different anomaly to 23 either the 14 Branch or 62 Branch Anomaly." 24 So those other two were the receipts and payments 25 mismatch bug and the suspense account bug, weren't they? 67 1 A. Yes. 2 Q. "The Falkirk Anomaly was the subject of expert evidence 3 in the 'Misra' criminal prosecution, where: 4 "a. the defence expert asserted that its existence 5 demonstrated Horizon had faults which could cause 6 losses, and therefore that possibility could not be 7 excluded in Misra's case." 8 "b. the prosecution expert (Gareth Jenkins from 9 Fujitsu) asserted that it could not have been 10 responsible for the losses because its clearly visible 11 events had not manifested themselves in the branch 12 records, and that it had been fixed more than a year 13 earlier." 14 Then it goes on to explain the outcome of the Misra 15 case. It also, at 32, refers to the Falkirk anomaly 16 having been: 17 "... considered by the High Court in December 18 2006/January 2007, when a subpostmaster (Lee Castleton) 19 raised it as part of his defence to a debt recovery 20 action for £23,000. 21 "The court found 'no evidence' of the Falkirk 22 Anomaly in [the] branch ..." 23 So, on the basis of the information contained in 24 this document, individuals within the Post Office knew 25 about the Falkirk bug by at least late 2006/early 2007; 68 1 was that your understanding? 2 A. I can only assume that's correct. 3 Q. Well, were you involved in creating this draft briefing? 4 It was certainly sent to you? 5 A. Yes, part of it. So yes, yeah. 6 Q. Can you help at all with the work that you did relating 7 to the Second Sight Review, so at this point in summer 8 2013, with how high up knowledge of the Falkirk bug in 9 2006/2007 went within the Post Office? 10 A. I don't know. 11 Q. Can we have on screen, please, POL00105632. There is 12 an email from Alwen Lyons to Paula Vennells, copied to 13 Martin Edwards, Mark Davies and Susan Crichton. It is 14 dated 23 May 2013 and the subject is "James brief". 15 Just for context there, the James brief, was that 16 referring to Lord Arbuthnot, who was then -- 17 A. I assume it does, yes. 18 Q. It reads as follows: 19 "Paula the only things that is not in the brief for 20 James is our move away from 'there are no bugs in 21 Horizon' to 'there are known bugs in every computer 22 system this size but they are found and put right and no 23 subpostmaster is disadvantaged by them' it would be good 24 to be able to go on and say 'or has been wrongfully 25 suspended or prosecuted'. 69 1 "I do not think that is a phone call conversation 2 but needs to be aired at some time with James, I would 3 suggest at your meeting." 4 I should stress you're not on the copy list to this 5 email, so you didn't receive it at the time, but drawing 6 together the evidence from this morning on Post Office 7 knowledge of bugs, errors, defects or issues with the 8 Horizon system, which could affect or might have 9 affected balancing in branch, it seems that, first, 10 individuals within the Post Office knew of the Falkirk 11 bug by at least late 2006/early 2007; would you agree 12 with that? 13 A. Yes. 14 Q. Second, there was Post Office knowledge of at least one 15 receipts and payments mismatch bug by late 2010? 16 A. Yes. 17 Q. You yourself, as Post Office Head of IT, knew about the 18 receipts and payments mismatch bug by at least March 19 2011? 20 A. Yes. 21 Q. Individuals within the Post Office knew about the 22 effects of the suspense account bug by February 2012, 23 even if the cause was not known at that stage? 24 Finally, issues relating to glitches in the quantity 25 function affecting branch accounts and large, 70 1 unexplained shortfalls had been raised with you and 2 others within the Post Office between September 2011 and 3 August 2012? 4 A. Yes. 5 Q. How can it be, therefore, that the public position of 6 the Post Office, up until May 2013, was "There are no 7 bugs in Horizon"? 8 A. I don't know the answer to that because, from my 9 perspective, as an IT professional, I wouldn't say there 10 were no bugs in any system, because you do -- and I call 11 them "faults", not "bugs" -- there are faults in 12 computer systems and it's important how you deal with 13 them. So when I read this email, I couldn't understand 14 it. 15 Q. Were you aware that that was the position being put 16 forward outside of the Post Office up until this point? 17 A. I don't recall what the position was at that time. 18 Q. Could we have on screen, please, POL00107955. This is 19 page 2 of this document, please. About halfway down the 20 page is the first email in this chain from Mark Davies 21 to Alwen Lyons, Simon Baker, Susan Crichton, Martin 22 Edwards and you, among others. It is dated 2 July 2013 23 and the subject is "Daily comms call". Mr Davies asks 24 Nina to set up a daily comms call on the Horizon issue 25 with all those copied and include Portland on it: 71 1 "If others need to be involved please can colleagues 2 suggest names." 3 Then the email above this, towards the bottom of 4 page 1, from Nina Arnott to those on the last 5 circulation list, along with a few others, including 6 Rodric Williams, this is also dated 2 July 2013, and she 7 says: 8 "No problem Mark. 9 "I appreciate it's tricky with everyone's busy 10 diaries. But in order to manage this reputational issue 11 most effectively, our top priority will be to ensure 12 everyone can attend one conference call a day for the 13 next four working days, to ensure there is one forum for 14 important decision making about our communications 15 approach, as publication date draws near." 16 The publication being referred to here, is that the 17 publication of the Second Sight Interim Report? 18 A. I believe it is. 19 Q. You then reply above, suggesting that Ms Arnott fixes 20 this for the best time and you manage around it -- 21 A. Mm-hm. 22 Q. -- and we can see a reply to you there from Nina. 23 What was your role in relation to the formulation of 24 the Post Office's public communications strategy about 25 Horizon's integrity? 72 1 A. So, I can't remember what involvement I had or didn't 2 have at this stage, and I've looked at this email and 3 I can't remember the meetings at the time. My input 4 would have been in terms of commenting on drafts or 5 documents. That's the best I can -- I can't -- I don't 6 even recall that, to be fair. That's what I would have 7 done. 8 Q. Could we have on screen, please, POL00341348. Starting, 9 please, towards the bottom of page 1. It is an email 10 from Simon Baker to you and Alwen Lyons, copied to Simon 11 Baker himself. It is dated 28 June 2013 and the subject 12 is "Summary of Receipts Payments problems". In his 13 email he sets out a timeline of events and then, at the 14 top of page 2, please, under "Problem Description", 15 there is this: 16 "The problem occurs as part of the process of moving 17 discrepancies into local suspense. 18 "There was a bug introduced as part of HNG, that in 19 certain circumstances meant that discrepancies were not 20 properly cleared to local suspense." 21 Going up, then, to the top of the first page of this 22 document, please, you reply on 29 June 2013 saying this, 23 two lines down: 24 "Can we change the reference from Bug to fault." 25 Before I ask you about that, I'd like to look at 73 1 just one more document from the day before, and that's 2 on 28 June 2013. Could we have on screen, please, 3 POL00296821. This is an email from Alwen Lyons to Mark 4 Davies, Hugh Flemington and you, copied to Rodric 5 Williams and Jarnail Singh, dated 28 June 2022, Subject 6 "14 Bug -- Wall". Alwen Lyons says: 7 "Can we call bugs incidents from now on please. 8 "Thanks 9 "Alwen." 10 This appears to be a response from an email from 11 Mark Davies below, on the same day, which says: 12 "Can we change the way we are referring to this 13 please as a matter of urgency?" 14 Was this correspondence on 28 June why you suggested 15 changing the reference from "bug" to "fault" in your 16 email on 29 June? 17 A. I don't know. All I can see is that my whole career 18 I've talked about "faults" and "issues". I've never 19 used the word "bugs". 20 Q. Could we have on screen, please, POL00380985. This is 21 an email from Mark Davies to Paula Vennells, dated 22 2 July 2013, and it's copied to you, among others, and 23 the subject is "Computer '?'s". Mr Davies is responding 24 to an email from Ms Vennells of the same date, just 25 below, which says: 74 1 "My engineer/computer literate husband sent the 2 following reply to the question: 3 "'What is a non-emotive word for computer bugs, 4 glitches, defects that happen as a matter of course?' 5 "Answer: 6 "'Exception or anomaly. You can also say 7 conditional exception/anomaly which only manifests 8 itself under unforeseen circumstances'." 9 Mr Davies responds above stating: 10 "I like exception [very] much. 11 "Very helpful." 12 What did you understand the concern to be about 13 using the term "bug"? 14 A. I really didn't understand the concern about using the 15 word "bug" or "fault" because that's what they were. 16 Q. Did you understand this to be driven by a desire to 17 minimise the seriousness of identified bugs by using 18 different language? 19 A. It appears that way. 20 Q. At the time, was that something that occurred to you or 21 not? 22 A. At the time, I thought it was -- I just thought it was 23 mad. 24 Q. Why do you say that? 25 A. Because they were faults, they weren't -- I wouldn't 75 1 have classed them as anomalies and, yes, it changed the 2 way in which we had to respond and communicate about 3 them, but they were faults. 4 Q. Could we have on screen, please, POL00145100. This is 5 an email from you to Martin Edwards, subject line "JA 6 meeting brief". Again, is that now Lord Arbuthnot? 7 A. Yes. 8 Q. There's a reference to a meeting brief for Paula 9 Vennells ahead of that meeting, and you say this: 10 "Martin 11 "Just to be clear on the anomalies -- these were not 12 undiscovered issues, we brought them to [Second Sight's] 13 attention for completeness. Also, when Susan and I were 14 crafting the briefing we were careful in our wording as 15 these were associated with potential losses to 16 [subpostmasters] in their trading statements. This was 17 so that we could differentiate from other issues -- 18 a good example is the PIN pads issue we had 3 years ago 19 which did get some publicity in the press. In addition, 20 Rod is reviewing another issue he raised with us on 21 Friday -- although he believes it did not affect 22 [subpostmasters] -- I've asked him to double check. 23 "We need to be careful in our comms not to indicate 24 that we do not have anomalies or exceptions as that is 25 not the case -- it's the context which is important and 76 1 in this case the fact that they could and did affect 2 trading statements." 3 So just to understand the issues and separate them 4 out in this, it appears that, by this point, you've 5 adopted the terminology of "anomalies" or "exception". 6 Was that because of the correspondence we've just been 7 to? 8 A. That's because we were asked to do that. 9 Q. Of course. 10 A. But, within IT, I would have talked about -- still 11 talked about "faults". 12 Q. So separately from the question of terminology, you 13 appear here to be drawing the distinction between 14 relevant bugs or faults, or whatever you want to term 15 them, and ones you considered not to be relevant -- 16 A. Yes. 17 Q. -- is that right? 18 A. Yes, that's right. 19 Q. Can you explain which ones you thought were relevant? 20 A. Which ones were relevant? 21 Q. So you've explained here -- you've made a reference to 22 the ones that could and did affect trading statements. 23 So was that the point you were trying to make? 24 A. That's -- yes, I was trying to make it really clear that 25 they did affect subpostmasters' trading statements and 77 1 this was with regard to the receipts and payments and 2 the suspense fault, effectively. 3 Q. Could we have on screen, please, POL -- 4 SIR WYN WILLIAMS: Before we do, sorry -- I may be chasing 5 a hare here, which is unnecessary but bear with me -- 6 there's been what I think at the moment some conflict in 7 the evidence about exactly who it was drew the attention 8 of Second Sight to these other -- to adopt your word, 9 Ms Sewell -- faults. You write in this email "We 10 brought them to SS attention for completeness". 11 When you used the word "we", can you remember who 12 you were referring to then? 13 A. I think IT did. 14 SIR WYN WILLIAMS: So you think someone in the IT Department 15 of the Post Office -- 16 A. Yes. 17 SIR WYN WILLIAMS: -- was the person or persons who actually 18 alerted Second Sight to these bugs or faults? 19 A. Yes, I do. 20 SIR WYN WILLIAMS: Fine, all right. 21 A. And, sorry -- 22 SIR WYN WILLIAMS: All right, that's fine. 23 Sorry about that but, as you know, Ms Price, there's 24 been -- not a degree of debate but uncertainty about who 25 said what to whom on this. 78 1 MS PRICE: Of course, sir. 2 Could we have on screen, please, POL00189880. 3 I appreciate, Ms Sewell, this is a document that has 4 been provided to you very recently, only this morning. 5 Have you had a chance to read through this and the other 6 two linked documents? 7 A. Very briefly. 8 Q. We'll take it fairly slowly, then. This is an email 9 dated 2 July 2013 from Mark Davies, Communications 10 Director, to you and others, and it encloses a draft 11 statement and it's called "Draft Press", so it appears 12 that it was a draft press statement; is that right? 13 A. Yes. 14 Q. Going to the attachment, POL00189881, we can see there: 15 "Confidential 16 "DRAFT Post Office statement on Horizon system." 17 This contains reference to the receipts and payments 18 mismatch bug and the suspense account bug, three 19 paragraphs up, please, from the bottom of the page. We 20 see there the reference in that paragraph, three 21 paragraphs up, to the 62 and the 14 branches affected. 22 The next paragraph underneath that says this: 23 "In the first of these cases, 17 subpostmasters were 24 adversely affected -- and later reimbursed -- to a total 25 cost of £xxx (with the highest payment being £115). In 79 1 the second set of cases, the total impact was xxx. 2 "The accounting anomalies in these cases were picked 3 up by the Horizon system, Post Office proactively 4 informed subpostmasters and any losses -- however 5 minor -- were reversed." 6 That reference to the accounting anomalies being 7 picked up by the Horizon system, that's not correct, is 8 it, that both anomalies were picked up by the Horizon 9 system? Because the suspense account bug was not 10 recognised as a bug and reported to Fujitsu by the Post 11 Office for a year after its effects were first reported; 12 would you agree with that? 13 A. Yes, I would. 14 Q. You provided comments on this draft statement. Could we 15 have on screen, please, POL00296993. We can see here 16 an email from Ruth Barker, on the same day, 2 July 2013: 17 "Here's the amended statement which I think 18 incorporates all comments and amends received so far." 19 It's to you and others. 20 Scrolling down to the email below, please, a little 21 further down, please, in the middle of the page there we 22 have an email from you, dated 2 July, to Nina Arnott, 23 Ruth Barker and others about the draft statement, and 24 you say: 25 "Nina 80 1 "Simon and I have gone through the detail with 2 Ruth -- she has our comments." 3 Then scrolling back up to the version of the draft, 4 which incorporates your comments, the fifth paragraph in 5 the amended draft, starting "The Horizon system", the 6 last sentence in that says "This evidence included", and 7 there's a reference there to the provision of 8 information to Second Sight. After that: 9 "The evidence included details two sets of 10 transaction anomalies -- one impacting 62 of the Post 11 Office's 11,800 branches between March and October 2010 12 and the other affecting 14 branches with respect to 13 accounting entries in 2010/11. 14 "In the first of these cases, 17 subpostmasters were 15 adversely affected -- and later reimbursed -- to a total 16 cost of £xxx pounds ... In the second set of cases the 17 total impact was xxx. When the accounting anomalies in 18 these cases were picked up by the Horizon system, the 19 Post Office proactively informed subpostmasters and any 20 losses, however minor, were reversed." 21 So the change here seems to be to "when the 22 accounting anomalies were picked up" in place of "the 23 anomalies were picked up by the Horizon system"; was 24 that a change you made to the wording? 25 A. So having just seen this, this morning, I didn't -- 81 1 I couldn't recall seeing this at the time. I obviously 2 did see it but I can't remember this. 3 Q. Do you see the problem that that still seems to be 4 incorrect -- 5 A. Yes. 6 Q. -- based on what we know about the suspense account bug? 7 A. Yes. 8 Q. Is that something that you should have corrected at the 9 time? 10 A. I can't remember reading it and I can't remember the 11 document, so I'm struggling with this, and I would have 12 relied heavily on Simon, as well, to help me as part of 13 this, because he was pulling together all the detail 14 on -- a lot of the detail on these particular faults. 15 Q. It's an important point, isn't it, because, if a bug can 16 go unrecognised for a year, a bug which causes 17 accounting discrepancies, the Post Office, which 18 dismisses, prosecutes and seeks to recover debt from 19 individuals on the basis of Horizon accounting data, 20 might go on to take action against individuals wrongly 21 before the bug is discovered as such, mightn't it? 22 A. It is an important point but I would never intentionally 23 leave anything out. I just wouldn't, sorry. 24 Q. Okay, do you want to take a break? 25 A. No, I'm fine. 82 1 SIR WYN WILLIAMS: We're about due our second break. 2 MS PRICE: We are, sir. I was just going to suggest that we 3 might want to take our break there. 4 SIR WYN WILLIAMS: Yes, we'll take ten minutes now so we'll 5 return at 12.25. 6 MS PRICE: Thank you, sir. 7 (12.16 pm) 8 (A short break) 9 (12.26 pm) 10 MS PRICE: Hello, sir. 11 SIR WYN WILLIAMS: Hi. 12 MS PRICE: Ms Sewell, just before we go back to the 13 documents, in answer to a question from the Chair 14 earlier, you said you thought that someone from IT told 15 Second Sight about the bugs. Can you help at all with 16 who from IT that was? 17 A. I think -- I think it was Simon Baker. 18 Q. Could we have back on screen, please, the document we 19 were just looking at, POL00296993. Just looking at the 20 draft, scrolling down a bit, please, the first paragraph 21 on the page: 22 "An interim review into concerns around the accuracy 23 of the accounting programme used in Post Office branches 24 has concluded there are no systemic issues inherent 25 within the computer system." 83 1 The point about Second Sight confirming that there 2 were no systemic issues in the computer system is 3 a point that you raise at paragraph 49 of your 4 statement, and I'd just like to explore that, please. 5 That document can come down. Thank you. 6 I'd just like to explore that, please, from an IT 7 perspective. In the context of bugs or defects 8 affecting a computer system, isn't any bug or defect 9 inherently systemic, in that all branches are on the 10 same software, even if all branches are not affected by 11 a bug? 12 A. So how I would look at it from an IT perspective, 13 systemic would affect everybody. So it would be quite 14 widespread. You do have, in all systems -- and I've 15 seen it throughout my career, where you can have 16 a fault, which will affect just small number of -- 17 I mean, in this case it's branches or accounts. You 18 know, if I think about my banking background. So 19 systemic to me is widespread. 20 Q. Referring to the lack of a systemic issue, using your 21 definition of systemic there, it doesn't engage, does 22 it, with the underlying point here that there were bugs 23 which could cause accounting discrepancies. One of the 24 bugs referred to in the Second Sight Report went 25 unrecognised, as such, for a year. There might well be 84 1 other bugs in a system of this size and scale which 2 occur; would you agree with those propositions so far? 3 A. Yes. 4 Q. In those circumstances, how could Post Office say that 5 its reliance on transaction data produced by Horizon to 6 dismiss, to prosecute, to seek to recover debt from 7 people had not caused the apparent losses, which were 8 the subject of challenge? We've seen in a number of 9 places quite bold statements that the Horizon system had 10 not caused the apparent losses which were the subject of 11 Horizon challenges. 12 A. Yes. 13 Q. How was Post Office in a position to say that? 14 A. So -- and I'll go back just from an IT perspective, for 15 any fault or issue that is raised, through whatever 16 means it's raised, the important point to maintain the 17 integrity of the data is to be able to identify and 18 rectify it. Now, that doesn't deal with potential 19 issues that you can't see because you're looking for 20 something that you can't actually see. But it's 21 important and, in these cases, these particular faults, 22 even though one took a year to deal with, it was 23 identified and it was corrected and the original issue 24 with the suspense one for the subpostmaster -- Willen, 25 I think it was -- the appropriate process control kicked 85 1 in, because it can't just be about the system; it's got 2 to be about the process, as well. 3 Q. Well, in that case, the Financial Services Centre had 4 looked at it and spotted that something wasn't right. 5 But do you recognise that there might be other cases 6 which were or weren't on the radar of Financial 7 Services, where there were apparent shortfalls which 8 weren't on Fujitsu's radar, which weren't on anyone's 9 radar? 10 A. That could have been a possibility but that then leads 11 on to how you check for the integrity of the data, and 12 I don't know whether we'll come on to that a little bit 13 later but that goes on to, well, how do you -- what are 14 the checks and balances in place as that data goes from 15 the terminal to the data centre itself and the database. 16 Q. In the context of prosecutions, you will be aware of 17 audit data requests that may have been made in support 18 of some prosecutions. 19 A. Mm-hm. 20 Q. But were you aware that there were other prosecutions 21 where no audit data was ever requested from Fujitsu? 22 A. Not to my knowledge. 23 Q. I'd like to move, please, to the question of Gareth 24 Jenkins and the evidence he gave in support of 25 prosecutions bought by the Post Office. Could we have 86 1 on screen, please, FUJ00156869. This is an email from 2 Harvey Michael, commercial director and solicitor at 3 Fujitsu, to someone called Helen Lamb, and it's dated 4 18 September 2013. The subject here is "Summary of 5 meeting with Post Office", and there is a list of 6 attendees and your name is on the list as attending. 7 A. Mm-hm. 8 Q. Having a look down the table that summarises that 9 meeting, do you recall being at that meeting? 10 A. I'm sorry, I don't. 11 Q. Going to point 7 from the summary, please, page 2, we 12 have this: 13 "[Post Office Limited's] criminal barrister from 14 Cartwright King solicitors has flagged a discrepancy 15 between the evidence given in court and the information 16 provided as part of the Second Sight audit. This could 17 mean that the relevant Expert is 'tainted'." 18 Then in the next column we have: 19 "I disagree that the expert is 'tainted' but 20 ultimately there is little point challenging it as we 21 agree it may be a sensible time to transition to a new 22 expert to ensure continuity of service." 23 Then there's an "Action": 24 "SC to determine whether she can share the report 25 with Fujitsu." 87 1 You appear to have been told at this meeting that 2 Post Office's criminal barrister from Cartwright King 3 had formed the view that the expert -- and that is 4 Gareth Jenkins -- was tainted because of a discrepancy 5 between the evidence he'd given in court and the 6 information provided to Second Sight. Were you aware at 7 the time that this was Gareth Jenkins? 8 A. Yes, I was. 9 Q. So you were aware of this opinion that had been given by 10 the barrister from Cartwright King? 11 A. I was aware probably from Sue Crichton. I can't 12 remember -- I don't recall seeing any legal review that 13 was done but I was certainly aware from Susan. 14 Q. Did this concern you at the time? 15 A. Yes, it would have concerned me at the time. I can't 16 remember what the concerns were exactly but it would 17 have been about -- because, as I understood it, he 18 hadn't disclosed all of the faults that he was aware of. 19 I think that was the material issue. 20 Q. Did anyone at this meeting -- and I recognise that 21 you're struggling to recall the meeting in particular -- 22 but did anyone from Fujitsu express concern about this? 23 A. I can't remember. 24 Q. Could we have on screen, please, FUJ00117284. This is 25 a "Business Review" of the Post Office Account dated 88 1 17 April 2015. Going to page 3, please, under "Customer 2 Satisfaction" that bottom left box, on the left-hand 3 side, if we can zoom in a little, please. You see the 4 last bullet point here is: 5 "Gareth Jenkins recognised by Lesley Sewell for 6 impeccable service and individual contribution." 7 So is this the same Gareth Jenkins who had been 8 described as a "tainted" expert in that meeting we've 9 just looked at? 10 A. It will be. 11 Q. Had it not negatively impacted upon your assessment of 12 him? 13 A. So any -- just by way of background, with calling out 14 individuals for any particular positive contribution to 15 Post Office, it's highly likely -- and I can assume that 16 the Inquiry will be able to find something that was 17 given to me -- to call Gareth out for a particular 18 reason. 19 Q. Can you recall what that was now? 20 A. No, I really don't and I can't actually recall. I think 21 this was about 2015, was it? What month was it, again? 22 Sorry. 23 Q. April, I think. 24 A. Right, okay. 25 Q. Yes. 89 1 A. I really don't know. 2 Q. Moving, please, to what has been termed "Remote access", 3 we looked earlier this morning at a meeting note of 4 a meeting in 2010, at which the receipts and payments 5 mismatch bug and potential solutions for dealing with it 6 were discussed. Could we have that back on screen, 7 please. It's FUJ00081945. This is the meeting at which 8 Mr Trundell from your team, or from IT, was in 9 attendance. 10 A. Mm-hm. 11 Q. Going to page 3, please. Under "Solution One" -- we see 12 that: 13 "There are three potential solutions to apply to the 14 impacted branches, the group's recommendation is that 15 solution two should be progressed." 16 One of the solutions being considered was "Solution 17 One": 18 "... Alter the Horizon branch figure at the counter 19 to show the discrepancy. Fujitsu would have to manually 20 write an entry value to the local branch account. 21 "Impact -- When the branch comes to complete next 22 trading period they would have a discrepancy, which they 23 would have to bring to account. 24 "Risk -- This has significant data integrity 25 concerns and could lead to questions of 'tampering' with 90 1 the branch system and could generate questions around 2 how the discrepancy was caused. This solution could 3 have moral implications of Post Office changing branch 4 data without informing the branch." 5 Did Mr Trundell, or anyone else at this meeting or 6 involved in discussions about this at the time, report 7 back to you that this was being contemplated? 8 A. I don't believe so. 9 Q. This makes clear, doesn't it, that Fujitsu could insert 10 data into the branch account without the branch's 11 knowledge or approval? 12 A. Yes, it does. 13 Q. Was that fact drawn to your attention at the time? 14 A. I don't believe it was. 15 Q. Should it have been? 16 A. Because I wasn't dealing with the issue itself, um -- so 17 there's two parts to this. I wasn't dealing with the 18 issue. I think, given what we know now and at the time, 19 it should have bubbled up and it should have gone all 20 the way up to Mike Young. 21 Q. But as Head of IT, as you were at the time, is this not 22 a material piece of information of which you should have 23 been aware? 24 A. This was an operational incident that was being dealt 25 with through a different line and, at the time I joined, 91 1 my role was largely changed. It wasn't dealing with 2 these issues. And Ian Trundell -- it's likely Ian would 3 be there just to support, with the reporting line going 4 separately through Andy into Mike. 5 Q. Setting aside the proposed solution, which we know 6 wasn't, in fact, the solution which was recommended or 7 adopted, the fact of the ability of Fujitsu to take the 8 step that was being proposed, wasn't that something you 9 should have been told about as Head of IT? 10 A. Probably, yes. 11 Q. Could we have on screen, please, POL00141531. Going to 12 page 2 of this document, please. Towards the bottom of 13 the page is an email from Simon Baker to Steve Beddoe, 14 copied to you. It is dated 22 May 2013, the subject is 15 "Branch database -- support team changes", and it reads 16 as follows: 17 "Steve 18 "Fujitsu tell me that very very occasionally the 19 support team are required to make updates directly to 20 the branch database (presumably to fix support 21 problems). 22 "And that when such a change is required, it is 23 signed off by [Post Office Limited] using the Service 24 Desk. 25 "Are you aware of this process? And if so, how do 92 1 I get a log of all such requests. 2 "Thanks, Simon." 3 The email above is to Antonio Jamasb from Simon 4 Baker, 24 May 2013. Antonio Jamasb was the person who 5 sent the meeting invite to the 2010 receipts and 6 payments mismatch bug meeting, wasn't he, and he 7 attended that meeting? 8 A. Yes. 9 Q. You're copied in here, and it says: 10 "Tony 11 "I know you are still working on this. As I am out 12 next week, can you keep Lesley in the loop as you get 13 a clear picture on the processes we use to approve 14 changes to live data, and a list of the times this has 15 happened. 16 "Also, Lesley is in Dearne and Chesterfield on 17 Thursday, if you are there she would appreciate a quick 18 conversation with you on this subject." 19 So you were being told in this email chain that 20 Fujitsu occasionally, or very, very occasionally, made 21 updates directly to the branch database. Could we have 22 on screen, please, FUJ00087027. This is an email from 23 4 June 2013. That appears, from the context and the 24 email below, to be the American format for dates because 25 we see the email below is 4 June. So, going up, please, 93 1 to that top email. You provide comment here on 2 providing Second Sight with answers to their questions 3 about remote access at the Bracknell site. Do you 4 remember that issue? 5 A. I do. 6 Q. The questions being asked are set out further down this 7 email chain, page 2, please, Ian Henderson's email of 8 3 June. There are a series of questions that are set 9 out there and then this, in the penultimate paragraph 10 underneath those: 11 "Please note that we're not really interested in 12 what the procedures manual says about any of this. We 13 need to look at whether it would be possible for a rogue 14 employee to do what is alleged and what log files would 15 be generated to record that activity. Please note that 16 I have now been provided with a second batch of employee 17 email and I may find the other emails that are 18 potentially relevant to this matter." 19 You were aware at this time, weren't you, of the 20 importance of this issue to the integrity of the Horizon 21 audit data? 22 A. Yes, I was. 23 Q. Could we have on screen, please POL00296795. This is 24 an email from Andrew Winn to you and others, dated 25 28 June 2013. It provides a summary of the history of 94 1 the receipts and payments mismatch issue. Attached to 2 Mr Winn's email was the note of the 2010 receipts and 3 payments mismatch meeting, at which the possible 4 solution of Fujitsu altering the branch data was 5 discussed. 6 When this was sent to you, would you have read the 7 attachments, the attached meeting note? 8 A. I don't know whether I would have read them. So I can't 9 remember the document that I saw in the pack, it didn't 10 spring any -- bring back any memories or anything, so 11 I can't remember it. 12 Q. You mean the 2010 meeting note? 13 A. Yes, the one you showed me earlier, yeah. 14 Q. Quite apart from the note of that meeting, you'd been 15 made aware, by this point, of the fact that very, very 16 occasionally Fujitsu would alter branch data, hadn't 17 you, in that earlier email we looked at? 18 A. So the earlier email we looked at and, again, I can't 19 recall having a discussion with Tony or seeing the 20 output from that email. It does reference data being 21 changed on the databases. But I don't know what that 22 was and whether it was transactional data or just -- you 23 know, you can make general support changes on 24 a database. 25 So I really don't know and I couldn't find anything 95 1 in the documentation that was provided to see what the 2 output of that was. I struggle to find anything. 3 Q. That document can come down now. Thank you. 4 SIR WYN WILLIAMS: When you say you struggle to find 5 anything, just so I'm clear, are you talking about your 6 struggle now, having read what's been sent to you -- 7 A. Yeah. 8 SIR WYN WILLIAMS: -- or struggle then, so to speak? 9 A. No, I struggle to see, from the documentation that was 10 provided by the Inquiry, Sir Wyn, to see what the output 11 of that was. But the only point I will add is that, 12 from the Inquiry notes that were sent, because this was 13 such a material issue, there was a meeting pulled 14 together with Second Sight to discuss this particular 15 point and I was obviously in attendance at that meeting, 16 and so was Fujitsu. 17 SIR WYN WILLIAMS: Hang on a minute. So there was a meeting 18 in or about the end of June/early July, is that when 19 we're talking about, 2013? 20 A. Yes, that's correct. 21 MS PRICE: Sir, there is a note of that meeting. 22 SIR WYN WILLIAMS: Yes, fine. I just wanted to be clear 23 what the witness was saying, that's all. Thank you. 24 MS PRICE: The note of the 2010 meeting on receipts and 25 payments mismatch, from that note, it appears that 96 1 Fujitsu was being upfront about the fact that it could 2 alter branch data in the way that was being proposed; 3 would you agree, having read that note now? 4 A. It does but I would counter that with the number of 5 times that I and others asked about branch data and we 6 were consistently given the same message: that it was 7 not possible. 8 Q. Could we have on screen, please, the Second Sight 9 Interim Report, that's POL00099063. Going to page 12, 10 please. This is dealing with spot review SR5, relating 11 to the Bracknell site allegation. Reference is made at 12 paragraph 1.4 to an assurance given in a letter to Alan 13 Bates in 2010, signed by Edward Davey MP, that there is: 14 "... no remote access to the system or to any 15 individual branch terminals which would allow the 16 accounting records to be manipulated in any way." 17 So that's the quote underneath there. 18 Over the page at 13, please, at 1.10(b), 1.10 said 19 "This review has shown", and at (b): 20 "An email sent to a number of [Post Office Limited] 21 employees in April 2011, including a member of the 22 Testing team in Bracknell, included the following 23 comment: 24 "'Although it is rarely done it is possible to 25 journal from branch cash accounts. There are possible 97 1 P&BA concerns about how this would be perceived and how 2 disputes would be resolved'." 3 Then at 1.11: 4 "'P&BA' refers to 'Product and Branch Accounting', 5 which is a team within [Post Office Limited] that is 6 responsible for the back office accounting system." 7 At 1.12: 8 "[Post Office Limited] has told Second Sight that 9 the comment noted above describes a method of altering 10 cash balances in the back office accounting system, not 11 Horizon. We note however that any changes to branch 12 cash account balances in this way would be subsequently 13 processed in Horizon using the transaction correction 14 process. This would be notified to [subpostmasters] and 15 requires their consent in order for the TC to be 16 processed. The TC process typically runs on 17 an overnight basis and is necessary to ensure that the 18 back office accounting system remains synchronised with 19 the Horizon system." 20 At 13: 21 "Second Sight notes that this method of ultimately 22 adjusting branch cash accounts in Horizon is similar, 23 but not identical to, what was described by the 24 [subpostmaster], albeit in an indirect rather than 25 a direct way. We have subsequently been told that none 98 1 of the [Post Office Limited] employees working in 2 Bracknell in 2008 had access to the back office 3 accounting system." 4 So Second Sight's understanding was clearly that the 5 only way that branch cash accounts could be adjusted was 6 through the back office accounting system of transaction 7 corrections, which would be notified to subpostmasters 8 and required their consent; would you agree? 9 A. Yes. 10 Q. The email we looked at from May, relating to the very, 11 very occasional intervention of Fujitsu, did you 12 understand that to mean that Fujitsu could alter the 13 branch accounts? Now, I know you've drawn a distinction 14 between fixing bugs but I just want to be clear about 15 this: before Second Sight published in July, were you 16 aware that Fujitsu employees, not P&BA, had the ability 17 to alter branch accounts? 18 A. To the best of my recollection, I didn't think that was 19 the case, that wasn't until the Deloitte report, which 20 was a year later. 21 Q. Could we have on screen, please, POL00108538. About 22 halfway down the page is an email from James Davidson 23 from Fujitsu, and this is dated 17 April 2014. It is 24 sent to Rodric Williams. The subject is "Strictly 25 Private & Confidential -- Subject to Privilege". 99 1 Mr Davidson is providing responses to a series of 2 questions which had been posed by Rodric Williams. 3 Going over the page, please, to question 2, the 4 question is: 5 "Can Fujitsu change branch transaction data without 6 a subpostmaster being aware of the change?" 7 The answer is: 8 "Once created, branch transaction data cannot be 9 changed, only additional data can be inserted. If this 10 is required, the additional transactions would be 11 visible on the trading statements but would not require 12 acknowledgement/approval by a subpostmaster, the 13 approval is given by Post Office via the change process. 14 In response to a previous query Fujitsu checked last 15 year when this was done on Horizon Online and we found 16 only one occurrence in March 2010 which was early in the 17 pilot for Horizon Online and was covered by 18 an appropriate change request from Post Office and 19 an auditable log. For Old Horizon, a detailed 20 examination of archived data would have to be undertaken 21 to look into this across the lifetime of use. This 22 would be a significant and complex exercise to undertake 23 and discussed previously with Post Office but discounted 24 as too costly and impractical." 25 Were you aware of this information in April 2014, at 100 1 the time that this email was sent? 2 A. It was a -- I think -- so the Deloitte report was 3 April/May and, at that point, it became very clear to me 4 that Fujitsu had actually inserted a transaction into 5 a Branch Trading statement. I wasn't -- 6 Q. I will come on to the Deloitte report in a moment, which 7 is May 2014. The information here from Fujitsu, 8 directly from Mr Davidson, did anyone raise that with 9 you in April 2014? 10 A. I don't recall it being raised with me and, if it had 11 been raised with me, I wouldn't intentionally not share 12 that sort of information because it's quite important. 13 Q. This is another document, isn't it, which suggests that 14 Fujitsu was being upfront about what was and wasn't 15 possible, in relation to changing branch transaction 16 data; would you agree? 17 A. Yes, it is. 18 Q. In May 2014, the Project Zebra draft report for 19 discussion was produced. You say at paragraph 53 of 20 your statement that you were heavily involved in Project 21 Zebra; is that right? 22 A. Yes, I was. 23 Q. Ahead of the publication of the report, the work being 24 done by Deloitte was discussed at a Post Office Limited 25 Board meeting on 30 April 2014. Could we have the 101 1 minutes of that meeting on screen, please. 2 I promise, sir, this will be brief before lunch. 3 The reference is POL00150285. 4 You see here the minutes, 30 April 2014, Post Office 5 Limited Board meeting and, on the first page, we can see 6 you were in attendance, scrolling down a bit, please, as 7 Chief Information Officer to address a particular issue, 8 so "(minute 14/55)", and then going, please, to page 6 9 of this document, the heading "Horizon -- Deloitte 10 Report", and at (a): 11 "The Board welcomed Lesley Sewell, Chief Information 12 Officer, and Gareth James, partner, Deloitte, to the 13 meeting. Chris Aujard also rejoined the meeting." 14 Then at (c) to (e), the minutes say this: 15 "Lesley Sewell explained that the first piece of 16 work Deloitte had been asked to undertake was to give 17 assurance that the control framework including the 18 security and processes for changes in the system, were 19 robust from an IT perspective. 20 "Gareth James reported that all of the work to date 21 showed that the system had strong areas of control and 22 that its testing and implementation were in line with 23 best practice. Work was still needed to assure the 24 controls and access at the Finance Service Centre." 25 At (e): 102 1 "Chris Aujard explained that several of the 2 subpostmasters who were challenging Horizon had made 3 allegations about 'phantom' transactions which were 4 non-traceable. Assurance from Deloitte about the 5 integrity of the system records logs would be very 6 valuable." 7 Were the discussions summarised here at (c) to (e) 8 referring to work on remote access or not? 9 A. I think (e) in particular, yes. 10 MS PRICE: Sir, if that's a convenient moment, I suggest we 11 might want to break for lunch now. 12 SIR WYN WILLIAMS: All right. Well, just one more question 13 from me. 14 A little while ago, you told me that you were 15 consistently being told that remote access was not 16 possible but I wasn't clear whether the persons telling 17 you that that was the case were Post Office personnel or 18 Fujitsu personnel, or both. 19 A. It was both. 20 SIR WYN WILLIAMS: It was both. Those were in direct 21 conversations? 22 A. From what I recall, yes. So, on one side, Post Office, 23 the Architects Team, and I think there's documentation 24 in the Inquiry pack, where you can see emails where I've 25 been given consistent messaging as well. 103 1 SIR WYN WILLIAMS: Given that you didn't begin at the Post 2 Office until -- I think it's April 2010, just so I can 3 be clear, was this in the period between April 2010 and 4 the publication of the Second Sight Interim Report or 5 was it a wider period, even than that, in the sense that 6 it went beyond the date of the publication of the Second 7 Sight Report? 8 A. So, to the best of my recollection, I think it went 9 beyond the Second Sight Report because we were trying 10 hard to get to the bottom of the Bracknell issue with 11 the testing. 12 SIR WYN WILLIAMS: Yes, all right. What time shall we start 13 again, Ms Price? 14 MS PRICE: 2.00, sir. It's only just past 1.00 now. 15 SIR WYN WILLIAMS: Yes, fine. 2.00. 16 MS PRICE: Thank you. 17 (1.04 pm) 18 (The Short Adjournment) 19 2.00 pm) 20 MS PRICE: Hello, sir, can you still see and hear us? 21 SIR WYN WILLIAMS: Yes, I can, thank you. 22 MS PRICE: Ms Sewell, before lunch we had just looked at the 23 board minutes from 30 April 2014 meeting and the 24 expectation that was expressed at that board meeting was 25 that Deloitte would be providing assurance about the 104 1 integrity of the system records logs, and that was in 2 the context of subpostmasters challenging Horizon. You 3 and Mr Aujard had been heavily involved in the Deloitte 4 work on Project Zebra, hadn't you? 5 A. Yes. 6 Q. You read the report when it was delivered? 7 A. Yes. 8 Q. Can we have the report on screen, please. The reference 9 is POL00107160. We can see the title on the front 10 "Horizon: Desktop Review of Assurance Sources and Key 11 Control Features". Scrolling down a bit, "Draft for 12 discussion", and the date, 23 May 2014. 13 Going to page 31 of this document, please. We have 14 here under (f) -- under this area "Key matters for 15 consideration" -- "Hardware controls over the audit 16 store". It says this: 17 "The Centera EMC devices used to host audit store 18 data have not been configured in the most secure EC+ 19 configuration. As a result, system administrators on 20 these boxes may be on able to process changes to the 21 data stored within the audit store, if other alternative 22 software controls around digital seals, and key 23 management are not adequately segregated from Centera 24 box administration staff. Privileged access to the 25 cryptographic solution around digital signatures, and 105 1 publicly available formulas on MD5 hashed digital seals 2 would potentially allow privileged users at Fujitsu to 3 delete a legitimate sealed file, and replacement with 4 a 'fake' file in an undetectable manner." 5 What did you think when you saw that Fujitsu could 6 delete a legitimate sealed file and replace it with 7 a fake file in an undetectable manner? 8 A. So, to the best of my recollection, I would have talked 9 to Deloitte about this particular finding and, to go 10 through it, it was a theoretical possibility, because 11 you would have had to have -- this was about the 12 administrators who looked after us after the hardware 13 itself and the administrators who would look after the 14 database itself, coupled with being able to digitally 15 seal and provide the MD5#, so you would have had to have 16 a number of people to collude in this. 17 The other point at this point in time, and I do 18 vaguely remember this, was my surprise at being able to 19 do that because my understanding had always been that -- 20 and I think I've covered this in my witness statement -- 21 that it was a WORM solution, so it was Write Once Read 22 Many times. So there was nothing you could do with that 23 audit store once it was -- once a transaction had been 24 applied to it. 25 Q. So this was something that you had hitherto thought not 106 1 possible? 2 A. Yes, that's right. 3 Q. Then, under (g) the first bullet: 4 "Branch database: We observed the following in 5 relation to the branch database being: 6 "A method for posting 'balancing transactions' was 7 observed from technical documentation which allows for 8 posting of additional transactions centrally without the 9 requirement for these transactions to be accepted by 10 subpostmasters (as 'transaction acknowledgements' and 11 'transaction corrections' require). Whilst an audit 12 trail is asserted to be in place over these functions, 13 evidence of testing of these features is not available 14 ..." 15 Then at the third bullet point: 16 "For 'balancing transactions', 'transaction 17 acknowledgements', and 'transaction corrections' we did 18 not identify controls to routinely monitor all centrally 19 initiated transactions to verify that they are all 20 initiated and actioned through known and governed 21 processes, or controls to reconcile and check data 22 source which underpin current period transactional 23 reporting for subpostmasters to the Audit Store record 24 of such activity." 25 Then at the bottom: 107 1 "Controls that would detect when a person with 2 authorised privileged access used such access to send 3 a 'fake' basket into the digital signing process could 4 not be evidenced to exist." 5 Again, what did you think when you read those 6 aspects of this report? 7 A. So this one was more material for me because it actually 8 demonstrated that a transaction had been inserted into 9 the branch database and, forgive me, because -- so I'm 10 trying to recollect from the papers that I was given as 11 part of the Inquiry -- and -- and it was, it was around 12 the balancing transaction, that was the material point 13 because I didn't think -- I didn't think it was 14 possible. 15 Q. This report established, did it not, that something that 16 Second Sight had been assured could not be done could 17 actually be done. 18 A. That's correct. 19 Q. Knowing the importance of the issue to the integrity of 20 Horizon audit data and given your involvement in dealing 21 with Second Sight, did you not think it was important to 22 bring this to their attention? 23 A. So, at the time, the business had, or Post Office had, 24 a separate -- it was a separate organisational structure 25 to deal with Second Sight and the person who was on that 108 1 organisational structure who was party to this was Chris 2 Aujard. So, whilst I didn't directly tell Second Sight 3 of this, I would have thought rightly, it would have 4 gone through that structure. 5 Q. Did you seek to identify any assurance work which needed 6 to be completed in response to the report? 7 A. So -- and I have a real gap with what happened after the 8 Deloitte report and largely because I haven't had that 9 much information provided by the Inquiry, and the second 10 half of that year was very heavy for me, in terms of 11 what was happening with separation and Fujitsu, as 12 an exiting supplier. From memory -- and these are very 13 vague memories -- I do remember the escalation(?) -- 14 I think that Information Security were heavily involved 15 in this, in terms of actions, and I've seen reference to 16 a meeting that I potentially attended, as well, at that 17 point. 18 But I have a real gap in terms of what did or didn't 19 happen after that. I'm really sorry. 20 Q. Do you recall who, within the Post Office, you discussed 21 the Deloitte report with? 22 A. Yes, I do. So I definitely spoke to Chris Aujard and 23 Paula Vennells. 24 Q. Could we have on screen, please, POL00031409. This was 25 the Project Zebra Action Summary. We can see there the 109 1 date, 12 June 2014. The author is James Rees; reviewer 2 Emma McGinn; review and sign off, Julie George. Do you 3 recall those individuals? 4 A. So I do recall Julie because I recruited Julie. 5 Q. What was Julie's role? 6 A. She was Head of Information Security. 7 Q. In essence, this is a document dealing with what the 8 organisation needed to do to meet the Deloitte concerns; 9 that's right, isn't it? 10 A. Yes, it is. 11 Q. If we go to page 6, please, and paragraph 4.2.2. This 12 is "Data Logging". It says: 13 "One point raised in the report was that it was 14 possible for someone with privileged access to delete 15 data from specific areas of Horizon. This is always 16 a risk with individuals using admin or power user 17 accounts and is a persistent risk, one that needs to be 18 catered for in almost any organisation. 19 "Due to the sensitive nature of the information 20 contained in the databases, monitoring of those 21 databases should be put in place using technology to 22 detect and record deletions and administrative changes 23 to the databases. If possible, alerts should also be 24 generated for mass deletions and high level risk changes 25 to database schemas. 110 1 "Recommended remediation: 2 "The solution currently in place may be able to 3 undertake the level of logging required within the 4 Horizon solution. It is recommended that the current 5 logging and logs are reviewed on a daily basis. 6 "This needs to be investigated further and the 7 options on how to handle this defined through the risk 8 management process and based on the solutions already in 9 place or ones that could be procured to handle this." 10 It's plain from this document, isn't it, that these 11 people in the Post Office understood that data could be 12 deleted, and that would not be immediately apparent to 13 the Post Office, let alone postmasters? 14 A. As part of the output from the Deloitte review. 15 Q. I'm talking in general terms, from this document 16 engaging with the Deloitte review. 17 A. Sorry, I've -- 18 Q. It's my fault. I'll repeat the question. 19 A. Oh, sorry. 20 Q. Looking at this document, which is engaging with the 21 Deloitte report, and we've been to the relevant 22 paragraphs in that, certainly the people who were named 23 on the front of the report understood that data could be 24 deleted, and that wouldn't be immediately apparent to 25 the Post Office or postmasters. 111 1 A. So how I've read that, since I've just received it, was 2 that this was related to the audit file, the Deloitte 3 report. 4 Q. Okay. 5 A. If you wouldn't mind just -- so I could re-read it -- 6 Q. Yes, we can scroll back up. 7 A. If you wouldn't mind because this document I did just 8 receive recently. 9 Q. Of course. If you scroll down to the bottom of page 6, 10 we're looking for 4.2.2. So the point here being 11 addressed is the one raised in the report, that it was 12 possible for someone with privileged access to delete 13 data from specific areas of Horizon. 14 So my question is: looking at that, which is 15 engaging with that aspect of the review, at least the 16 individuals, on the face of this summary document, were 17 aware of this fact at this point, that it was for 18 someone with privileged access to delete data from 19 specific areas of Horizon? 20 A. So that's how it reads. 21 Q. Did you see this document in 2014? 22 A. I can't recall seeing it. As I've said, I've got a real 23 memory gap between the Deloitte report and into 2015. 24 I've just got a real gap -- gap there and it's largely 25 because of probably everything else that was under way 112 1 at the time. 2 Q. Could we have on screen, please, POL00346958. This is 3 an email from Julie George, whose name was on the review 4 and sign off for that report we've just looked at. It's 5 dated 17 June 2014 and it's to Rod Ismay, David Mason, 6 Malcolm Zack, copied to Gina Gould. She says this, and 7 is attaching Zebra Action Summary version 0.3: 8 "Hello all, 9 "I have tried to call you Rod -- attached a Draft 10 Summary of actions arising from Deloittes recent piece 11 of work on the Horizon systems. 12 "Clearly there is no blame attached anywhere, and 13 this morning's meeting with Chris Day, Chris Aujard, 14 Lesley and Malcolm -- focused on what we would need to 15 put in place as an organisation to address overall 16 assurance on all critical systems, starting with Horizon 17 from 1 April. 18 "Detailing appropriate industry standards and 19 controls our business should be following against a risk 20 based priority mechanism. 21 "Rod we would be happy to come to Chesterfield, 22 however it would be better (more cost effective) if we 23 could have a morning or afternoon in the next week or so 24 at Old Street. 25 "We 4 will need to be comfortable that we have 113 1 a plan going forward including indicative costs of 2 undertaking for Risk and Compliance Committee on 3 21 July. 4 "We will need to engage with the ExCo members 5 attached to verify and agree to support prior to the 6 committee meeting." 7 Then asking Gina to arrange a meeting between Rod, 8 Dave, Malcolm and her. 9 So it appears from this that you had, that morning, 10 been at a meeting to discuss this with, among others, 11 Chris Aujard. Does that help with you are recollection 12 of involvement at this stage? 13 A. So I must have been at a meeting but I'm really 14 struggling to remember it. 15 Q. Can you help at all with whether the recommendations 16 were implemented by 1 April the following year? 17 A. I'm sorry, I can't. 18 Q. That document can come down now. Thank you. 19 In 2015, Paula Vennells was seeking assistance on 20 remote access in advance of her attendance before the 21 Select Committee; do you recall that? 22 A. I vaguely recall it. 23 Q. Could we have on screen, please, POL00029812. Looking 24 first, please, at page 5 -- scrolling down, please -- we 25 have an email from Paula Vennells, 30 January 2015, 7.29 114 1 in the morning, and this is to Mark Davies and to you, 2 subject "Urgent: Accessing Horizon". She says this: 3 "Dear both, your help please in answers and in 4 phrasing those answers, in prep for the [Select 5 Committee]: 6 "1) 'is it possible to access the system remotely? 7 We are told it is'. 8 "What is the true answer? I hope it is that we know 9 this is not possible and that we are able to explain why 10 that is. I need to say no it is not possible and that 11 we are sure of this because of xxx and that we know this 12 because we have had the system assured. 13 "2) 'you have said this is such a vital system to 14 the Post Office, what testing do you do and how often? 15 When was the last time?'" 16 Then underneath this: 17 "Lesley, I need the facts on these -- I know we have 18 discussed before but I haven't got the answer front of 19 mind -- too many facts to hold in my head! But this is 20 an important one and I want to be sure I do have it. 21 And then Mark, to phrase the facts into answers, plus 22 a line to take the conversation back up a level -- ie to 23 one of our narrative boxes/rocks." 24 "Thanks, Paula." 25 The answers to those questions are set out in the 115 1 emails which are further up in this email chain. So if 2 we can just go through them. The one above, this is 3 from Kevin Lenihan, 30 January, to Pete Newsome: 4 "Pete, 5 "My phone call earlier today refers. 6 "I need some urgent information as per Paula's note 7 please." 8 Then above: 9 "Mark, 10 "As discussed, can you hook up with Kevin to review 11 what answers have already been provided to Second Sight 12 as this should form the Post Office response." 13 Then up again, we have an email here from Mark 14 Underwood to James Davidson, copied to Kevin Lenihan, 15 and he says -- apologies, if we can just scroll down, 16 please, to the bottom of this email. 17 Going back up again. There's no sign off there. 18 Who was Mark Underwood? 19 A. I don't know who Mark Underwood was. 20 Q. He says: 21 "Hi Kevin my proposed answer to the first question 22 below (it can be sent in its entirely to Mel and she can 23 pick and choose). Though this will need to be signed 24 off by James as accurate [so James Davidson]. 25 "In terms of second question, I cannot find anything 116 1 on the testing carried out. It could very well have 2 been sent to one of my predecessors but I cannot find it 3 anywhere." 4 Then "In terms of [question] 1: 5 "This question often phrased by applicants and 6 Second Sight is: 7 "'Can Post Office remotely access Horizon?'" 8 The answer: 9 "Phrasing the question in this way does not address 10 the issue that is of concern to Second Sight and 11 applicants. It refers generically to 'Horizon' but more 12 particularly is about the transaction data recorded by 13 Horizon. Also, the word 'access' means the ability to 14 read transaction data without editing it -- Post 15 Office/Fujitsu has always been able to access 16 transaction data however it is the alleged capacity of 17 Post Office/Fujitsu to edit transaction data that 18 appears to be of concern. Finally, it has always been 19 known that Post Office can post additional, correcting 20 transactions to a branch's accounts but only in ways 21 that are visible to subpostmasters (ie transaction 22 corrections and transaction acknowledgements) -- it is 23 the potential for any hidden method of editing data that 24 is of concern. 25 "Can Post Office or Fujitsu edit transaction data 117 1 without the knowledge of a subpostmaster? 2 "Post Office confirms that neither it nor Fujitsu 3 can edit transaction data without the knowledge of 4 a subpostmaster. 5 "There is no functionality in Horizon for either 6 a branch, Post Office or Fujitsu to edit, manipulate or 7 remove a transaction once it has been recorded in 8 a branch's accounts. 9 "The following safeguards are in place to prevent 10 such occurrences: 11 "Transmission of baskets of transaction data between 12 Horizon terminals in branches and the Post Office data 13 centre is cryptographically protected through the use of 14 digital signatures. 15 "Baskets must net to nil before transmission. This 16 means that the total value of the basket is nil and 17 therefore the correct amount of payments, goods and 18 services has been recorded in the basket. Baskets that 19 do not net to nil will be rejected by the Horizon 20 terminal before transmission to the Post Office data 21 centre. 22 "Baskets of transactions are either recorded in full 23 or discarded in full -- no partial baskets can be 24 recorded to the audit store. 25 "All baskets are given sequential numbers ... when 118 1 sent from a Horizon terminal. This allows Horizon to 2 run a check at the data centre for missing baskets ... 3 or additional baskets that would cause duplicate numbers 4 ... 5 "All transaction data in the audit store is 6 digitally sealed -- these seals would show evidence of 7 tampering if anyone, either inadvertently, intentionally 8 or maliciously, tried to change the data within a sealed 9 record." 10 Then: 11 "Automated daily checks are undertaken on JSNs 12 (looking for missing/duplicate baskets) and on the 13 digital seals (looking for evidence of tampering)." 14 Going down, please. Then we go back up to the email 15 above this. 16 Kevin Lenihan then sends this to Mark Underwood, 17 James Davidson, Melanie Corfield, also on 30 January 18 2015. This provides bullets in relation to question 2. 19 Just going up again, please. Then we have this from 20 Kevin Lenihan and this is the final answer in an email 21 from Kevin Lenihan to Mark Underwood, Melanie Corfield, 22 copied to Pete Newsome, Dave Hulbert, you, Dave King, 23 Julie George, James Davidson. It says, "Update 24 [Question 1]: URGENT ACTION: Accessing horizon": 25 "Mark/Mel, 119 1 "James has had a look at your answer to [Question 2 1]. And thinks there's too much detail for Paula -- 3 this was written for a different type of audience. He 4 has captured the same points but in a more appropriate 5 format: 6 "He states: 7 "Having looked again at the request from Paula, it 8 appears that the fundamentals around this question 9 (remote access) are not understood. I suggest that 10 Paula is briefed along the lines of the following. 11 "1) No transaction data is held locally in any 12 branch. Transactions are complete and stored in 13 a central database and copies of all data is sent to 14 a secure audit database. 15 "2) Subpostmasters directly manage user access and 16 password setting locally so system access (to create 17 transactions) are limited to approved local personnel 18 only who are responsible for setting their own 19 passwords. Users are only created following an approval 20 process. All subsequent transactions are recorded 21 against the ID used to log on to the system. 22 3) Once a transaction has been completed, there is 23 no functionality (by design) for transactions to be 24 edited or amended. Each transaction given is a unique 25 number and 'wrapped' in a digital encryption seal to 120 1 protect if its integrity. All transactions are then 2 posted to a secure and segregated audit server." 3 Then fourth: 4 "On approval, there is the functionality to add 5 additional transactions which will be visible and have 6 a unique identifier in the audit trail. This is 7 extremely rare and only been used once since Go Live of 8 the system in 2010 (March 2010). 9 "5) Support staff have the ability to review event 10 logs and monitor, in real time, the availability of the 11 system infrastructure as part of standard service 12 management processes. 13 "6) Overall, system access is tightly controlled by 14 industry standard 'role based access' protocols and 15 assured independently in annual audits for ISO 27001, 16 Ernst & Young for IAS 3402 and as part of PCI audits." 17 Then at the bottom: 18 "Mel/Mark -- I'll assume that you are okay with this 19 final position, unless I hear differently. James has 20 advised that he is contactable over the weekend ..." 21 So going up to the top, please, we can see this was 22 copied to you. On reading this email and knowing what 23 you knew at the time from the Deloitte report, do you 24 think that this information being provided was accurate? 25 A. The point around the balancing transaction, I understood 121 1 it as being accurate. 2 Q. Well, let's have a look at which point you're referring 3 to. Scrolling down, please. 4 A. So it's point 4. 5 Q. So number 3: 6 "Once a transaction has been completed, there is no 7 functionality (by design) for transactions to be edited 8 or amended", et cetera. 9 Then there's the fourth point, which is 10 an exception, in effect: 11 "On approval, there is functionality to add 12 transactions which will be visible and have a unique 13 identifier in the audit trail ... extremely rare ..." 14 There is no mention here, is there, of the ability 15 to delete transactions, for example, casting your mind 16 back to the points we read about in the report? 17 A. There isn't and I can remember, and I can see in the 18 documents I was provided with, that -- and so, from the 19 Deloitte report to January, I have a real gap, because 20 I can't remember what the actions were taken, and that's 21 with deep regret from my perspective. 22 The action -- I actually asked Julie George, who was 23 the Head of Information Security, because I can see from 24 the emails that I've been provided with, I wanted to 25 make sure that it was accurate information and I wasn't 122 1 close enough at that time, because of everything else 2 that was going on, and it was a particularly difficult 3 time for me. I wanted to make sure that it was 4 accurate, the information that was being provided. 5 I can't remember the point about the deletion and 6 it's with regret, if I have forgot it. But I had asked 7 the experts, who were close to this on a day-to-day 8 basis, to provide the necessary information. So I felt 9 as if I had acted correctly in doing that. Sorry. 10 Q. Of course. Do you want to take a break? 11 A. No, I'm fine. It's okay. 12 Q. If we can scroll up to the top, please, of this 13 document. Just for completeness, we can see Melanie 14 Corfield there, Friday, 30 January -- scrolling down 15 a bit, please, so we can see: 16 "Thanks again to everyone. This all provides the 17 reassurance needed for Paula in my view re any 18 [questions] that come up on this. If we get more 19 queries on any aspect I will let you know." 20 That email seems, doesn't it, as though Ms Corfield 21 has read the email below, at least to provide the 22 reassurance that Paula Vennells was seeking in that 23 original email, ie "No, this is not possible because"; 24 would you agree? 25 A. That's what it appears. 123 1 Q. Then the top email, Dave Hulbert, who is Head of IT 2 Services by this point: 3 "Kev 4 "Good outcome and thanks for pulling all of this 5 together. Really appreciated." 6 That's to him and to you. 7 Again, for completeness, we could have on screen 8 please POL00162308. Scrolling down, please, so we can 9 see the email below, we can see that's the email we've 10 just been through the detail of from Kevin Lenihan, 11 looking at the answer to question 1, just scrolling down 12 so we can see that. Then going back up, please, to the 13 top, that then appears to be forwarded by you to Mark 14 Davies, do you see that, on Friday, 30 January? 15 A. Yes. 16 Q. There are no comments on that from you. Did it occur to 17 you at the time that this was inaccurate in any way? 18 A. My point of reference at this point or the last point of 19 reference was the balancing transaction, and I can't 20 recall actually reading that -- I must have read it if 21 I've sent it on, but I can't -- reading it now, it's in 22 there the balancing transaction. It probably should 23 have been clearer. 24 MS PRICE: Sir, those are all the questions that I have for 25 Ms Sewell. There are some questions from Core 124 1 Participants. I wonder if we might take the afternoon 2 break early at that point, just so that I can establish 3 who and in what order, and time estimates. 4 SIR WYN WILLIAMS: Yes, by all means. That sounds fine. 5 MS PRICE: Sir, if we can take 15 minutes now, sir, we are 6 not pressed for time, coming back at 2.50, please. 7 SIR WYN WILLIAMS: Yes, fine. 8 MS PRICE: Thank you. 9 (2.34 pm) 10 (A short break) 11 (2.50 pm) 12 MS PRICE: Hello, sir. 13 SIR WYN WILLIAMS: Hello. 14 MS PRICE: We have questions from Ms Page and from 15 Mr Moloney. Ms Page will be no more than 30 minutes and 16 Mr Moloney will be no more than 10 minutes. 17 SIR WYN WILLIAMS: All right. 18 MS PRICE: Thank you, sir. 19 Questioned by MS PAGE 20 MS PAGE: Thank you. Ms Sewell, would you say that there 21 were cliques within the Vennells/Perkins management 22 regime? 23 A. Sorry, I didn't catch that. 24 Q. Would you say that there were cliques within the 25 management regime under Ms Vennells and Ms Perkins' 125 1 leadership? 2 A. Cliques, as in? 3 Q. Were there people who were in favour, people who then 4 fell out of favour? 5 A. I'm -- sorry, apologies. I'm just trying to think to 6 answer your question. I don't know whether I would call 7 them cliques but there was -- certainly you would have 8 different groups of people who would come together. 9 Q. You describe in your witness statement at paragraph 10 73 -- and I don't need to take you to it -- how you fell 11 out of favour, if you like, and how you felt you were 12 isolated and unable to do your job. Now, I don't want 13 to distress you unnecessarily but that's how things -- 14 A. Sorry, that particular period was very difficult for me 15 and it still is very difficult. So I'm really sorry 16 that I'm getting upset about it. 17 Q. Don't worry. Don't worry. 18 All I'm trying to get clear about is that that was 19 an example, perhaps, of the way sometimes people would 20 get the cold shoulder and find themselves on the 21 outside; is that fair? 22 A. Well, I did feel on the outside at that point. 23 SIR WYN WILLIAMS: Can I ask you just approximately from 24 when you felt on the outside, just so I can have some 25 idea of it. I don't need the details of it, just -- 126 1 A. It was probably late 2014. 2 SIR WYN WILLIAMS: Right. Thank you. 3 MS PAGE: Now, you also described earlier today how you 4 effectively fell in with using the word "anomaly" even 5 though, in your own words, that was a "mad" word to use 6 and the correct word was "fault"? 7 A. Yes, that is correct. 8 Q. Do you think that's the sort of thing that happens in 9 a management environment where people have to curry 10 favour, people have to get on the right side of those 11 above them? 12 A. So I didn't do that to curry favour. That was 13 a direction that we were asked to take. So it wasn't 14 about myself trying to curry favour. 15 Q. All right. You also told us that no one had taken 16 ownership of the 2011 EY audit, which had various 17 actions following. So that's the first of two topics 18 that I want to take you to overall. Just to refresh, 19 that audit in 2011, it exposed some problems around 20 keeping track of who could access what within the 21 Horizon system? 22 A. Yes. 23 Q. The EY management letter said: 24 "This may lead to the processing of erroneous or 25 unauthorised transactions." 127 1 A. Yes. 2 Q. All right. Now, in January of the following year of 3 2012, there was an RMG Internal Audit report, which 4 picked up on some of the actions from that; do you 5 remember that? 6 A. Yes, because I requested it. 7 Q. You actually requested that, did you? 8 A. Yes, I did. 9 Q. Well, that's helpful to know. All right, let's have 10 a look at that. That's POL00030217. When we get there 11 I want to start, first of all, by going to page 7 where 12 we see the names -- 13 Oh, sorry, I've given the wrong reference, 14 POL00029114. I'm so sorry. That's the management 15 letter but we don't actually need to go to that. So if 16 we scoot down to page 7, we'll see the names of those 17 who received this report. 18 We can see on the left, these are the POL names: 19 Susan Crichton, Christopher Day, Kevin Gilliland, Andy J 20 Jones -- that's probably a relatively new name for the 21 Inquiry -- Neil Lecky-Thompson, you, Paula Vennells -- 22 at that point Managing Director, so this is 23 pre-separation, isn't it -- and Mike Young, Chief 24 Operating Officer. 25 Now, am I right in saying that, on the right-hand 128 1 side, those are RMG names: Derek K Foster, Internal 2 Audit; Moya Greene, Chief Executive of RMG; is that 3 right? 4 A. So I recognise some of those names but not all of them. 5 Q. Am I right in saying Moya Greene, Chief Executive of RMG 6 rather than POL. 7 A. Yes. 8 Q. Then we've also got Chief Financial Officer, Chief of 9 Staff, Head of Risk, and then Ernst & Young themselves, 10 of course -- 11 A. Yes. 12 Q. -- the people who had written the audit and management 13 letter. All right, so those are the recipients. 14 If we could perhaps have a look first at page 9., 15 what we see is the heading "Appendix B -- Update on 16 Actions Arising from 2011 E&Y Audit". So that's pretty 17 clear of what's going on there: that's a summary of what 18 E&Y had recommended; am I right? 19 A. Yes. 20 Q. What we see on the right-hand side is the status of the 21 actions? 22 A. Yes. 23 Q. We've got "Substantial progress made" or "Further work 24 required" against each of them. 25 A. Yes. 129 1 Q. Is that fair? 2 A. Yes. 3 Q. All right. If we now go back, please, to page 3, we 4 don't need to read all of this page at all but what we 5 can see is there's a sort of a summary of key findings 6 and, in the bottom half, "E&Y Management Letter", is the 7 heading and then, if we look down towards the single 8 line paragraph below that, it says: 9 "The findings, summarised in Appendix B on page 9 10 [which is what we've just looked at], have been shared 11 with E&Y and reflect our assessment as at the end of 12 January 2012." 13 Then we see below that, a line "Management 14 Response": 15 "We agree with this report and its findings, and 16 will act to progress the action within the agreed 17 timescales." 18 That's your response, your management response? 19 A. Yes. 20 Q. All right. So there we are, January 2012, and all the 21 actions either say, "Substantial progress made" or 22 "Further work required"; all right? 23 A. Yeah. 24 Q. Now, what I want to do is go forward a little bit to May 25 2012 and to a briefing paper and the paper reference 130 1 POL00143075. At the top there, we can see it says it's 2 a "Briefing for Paula Vennells (Chief Executive) and 3 Chris Day (chief Financial Officer)", and it's about the 4 "Post Office IT General Controls, Ernst & Young Audit 5 2011/12". 6 Now, bearing in mind, of course, that Paula Vennells 7 was one of the recipients of that RMG Internal Audit 8 report that we've just looked at -- 9 A. Yes. 10 Q. -- if we just confirm, if you'd like me to -- or maybe 11 you don't need me to. If we see at page 3 that's got 12 your name at the end and the date is 2012 on that paper; 13 do you remember doing this? 14 A. Well, I've just received this in the last few days. 15 Q. Oh, I see. 16 A. Yeah. 17 Q. So does it ring any bells? Did it ring any bells when 18 you read it in the last few days? 19 A. It didn't but I was absolutely involved in it. 20 I couldn't remember the detail. 21 Q. What I want to take you to is a bit of an anomaly 22 because, if we look on page 3 and if we look 23 specifically -- I'm so sorry, page 2, paragraph 3.4. So 24 if we just look at paragraph 3.4, it refers to that 25 Royal Mail Group audit and it says: 131 1 "Through an independent Royal Mail Group audit 2 conducted on the Post Office systems (November 2011), it 3 was agreed that all actions had been completed as 4 planned. Two actions had minor activities still to be 5 completed, which were addressed by December 2011." 6 So that's at odds, isn't it, with what we just 7 looked at, which said that everything was still pretty 8 much outstanding in January 2012. Have you got anything 9 to help us understand that anomaly? 10 A. So I don't but I can see in the appendix it included of 11 the observations. 12 Q. It does indeed. We'll go down to that because that is 13 also rather odd. If we go down, please, to page 4, 14 appendix A, "Summary status of the 2010/11 audit 15 observations -- as agreed with the RMG independent audit 16 in November 2011". 17 Now, I hope you'll take it from me that everything 18 below that, the finding numbers, the E&Y ratings, the 19 summary of actions, is the same as the appendix to the 20 RMG audit but you'll see there, on the right-hand side, 21 instead of those words "Substantial progress made" or 22 "Further work required", where "Substantial progress" 23 was the wording, it's now just the colour green, and 24 where "Further work was required", it's now just the 25 colour yellow, and so that rather obscures, doesn't it, 132 1 that there was still plenty of work to be done in 2 January 2012? 3 A. So I don't -- I really don't recall that and I think 4 it's unusual for it not just to be lifted. 5 Q. Was this briefing something that Ms Vennells asked for, 6 do you think? 7 A. I have some vague memory of Chris asking for it but, 8 again, I've got nothing to substantiate that. It's very 9 vague. 10 Q. This was the month after Post Office had separated from 11 Royal Mail Group and there was an ARC meeting, the first 12 ever ARC meeting, in this same month. 13 A. Right. 14 Q. Do you think you got the message that loose ends had to 15 be tidied up? That something needed to be done to make 16 it seem like everything had been actioned when it 17 hadn't? 18 A. No, I don't recall anything of that nature. I think, 19 just by way of context, the '11/'12 audit was 20 a difficult audit because the '11, or '10/'11 audit 21 reported late, and so actions were put in place 22 throughout that year. So some actions were completed 23 part way through a year, not for a full year, and it 24 wasn't until the following year that you actually saw 25 the impact of all of the actions, completed actions, 133 1 taking effect. 2 Q. Would you accept that it was important for POL, at this 3 point when it was separating, to get a grip? As you 4 said yourself, somebody needed to take ownership of the 5 actions, didn't they? 6 A. Absolutely, and I've said that in my witness statement. 7 Q. Also in your witness statement you refer at 8 paragraph 79 -- and I will take you to this, please -- 9 at page 40, to a call that you had with Ms Vennells in 10 2021. That was requested by her and you took some 11 notes, didn't you? 12 A. That's correct. 13 Q. That's 12 April 2021? 14 A. Yes. 15 Q. Now, I won't read out the whole of the paragraph. If we 16 see there's a line there: 17 "Paula contacted me again on 12 April 2021 via text 18 message requesting a call. We spoke for longer ... and 19 I made a file note", and I'll take you to that shortly. 20 You say that there are a few things that perhaps 21 seem to be the issues. First of all, it's about the 22 Project Zebra Deloitte report and then, if we scroll 23 down a little bit, there's a reference to your note 24 saying, "PV got jumpy", and that seemed to be in 25 relation to the Deloitte report. But it then says, 134 1 "I can see reference in my notes to the EY audits". 2 So if we just go to your notes, please, it's 3 WITN00840103, and if we go to page 2, please. We can 4 see in that first rectangular box that you've drawn "EY 5 audited controls" and then a bit further down we've got: 6 "2012/2013 -- no material. 7 "Overall control environment not sufficient general 8 IT controls." 9 So, evidently, part of this conversation was about 10 this period, wasn't it, when you had done the work to 11 get the RMG Internal Audit, you had taken control and 12 taken ownership. Can you tell us anything about what 13 Ms Vennells wanted to say to you about all of that in 14 this call? 15 A. I can't remember specifically about the detail of what 16 was discussed. I can vaguely remember the discussion 17 around the ISA 342 (sic), and getting to that position 18 and, again, I had no material, so I had nothing to refer 19 to, and I think there was reference to a number of 20 issues which had come out of the earlier audits, but 21 I can't remember any detail other than that. I'm sorry. 22 Q. You felt sufficiently uncomfortable, after that, to 23 actually block Ms Vennells; is that right? 24 A. Yes, I did. 25 Q. If I can move, please, to the second topic that I wanted 135 1 to ask you about. This is about your investigations -- 2 that sounds more formal perhaps than it is -- you 3 looking into the receipts and payments mismatch bug in 4 2013 when POL was responding to the Second Sight Interim 5 Report, and I ask these questions specifically on behalf 6 of my client Seema Misra, whose name I'm sure you know. 7 I want to explore the information you may have heard 8 about whether that bug was disclosed in her trial. All 9 right? 10 First of all, I want to go to POL00371710. If we 11 scroll all the way down on this chain when we get there, 12 please. That first email in the chain is from Gareth 13 Jenkins to you, providing you with his witness statement 14 in the Misra case and he explains a little bit about it, 15 and it's evident that he's talking about a different bug 16 that was disclosed during that case. We've come to know 17 it as either the Falkirk bug or the Callendar Square 18 bug. He says he's happy to dig out anything more and he 19 says the key point is Horizon did have bugs discussed in 20 court but POL won the case. 21 If we go up a bit, please, to the next email -- 22 sorry, just to confirm, that's on 28 June. You forward 23 that to Alwen Lyons, Martin Edwards and Mark Davies. 24 Mark Davies, we can see, picks up on it: 25 "This is massively important. 136 1 "Is there also a possibility that all incidents -- 2 14 and [16] [that's the two bugs] -- have been 3 referenced in court?" 4 The 64 is the receipts and payments mismatch bug, 5 isn't it? 6 A. Yes. 7 Q. So if we go a little bit further up, Alwen Lyons says, 8 "14 unlikely": 9 "Hugh, can we check, or is it quicker to ask Gareth, 10 Lesley." 11 So I think that's a question to you, really? 12 A. Yes. 13 Q. Then you respond "Will ask FJ", and that's on 28 June. 14 That's a Friday. 15 If we go to the next email, it's POL00137323, 16 page 1. We only need to look at your email on page 1. 17 This is on the Monday following that Friday, which is 18 1 July and it's at 12.57. You say to Hugh Flemington, 19 Alwen Lyons, Simon Baker and Rodric Williams: 20 "I asked the question of FJ if either ..." 21 I won't take you to it, I hope you'll take it from 22 me, you're meaning either of the two bugs: 23 "... had been referenced in any of the cases, 24 regarding these two issues -- the answer is no." 25 Do you know who you asked at Fujitsu? 137 1 A. I don't but I do want to say I feel so deeply about all 2 of the subpostmasters and your client, in particular. 3 Q. I know you're doing what you can, so -- 4 A. But I can't remember who I asked in Fujitsu. 5 Q. Did you have a direct relationship with Gareth Jenkins? 6 A. No, I didn't. 7 Q. So when he sent you that email with his witness 8 statement from that case attached, was that unusual? 9 A. It was very unusual and I think I've said that in my 10 witness statement. 11 Q. So you don't think -- I'm just speculating, maybe 12 I shouldn't: do you think you would have contacted 13 Gareth Jenkins to ask him? 14 A. I really don't know because my main contacts at Fujitsu 15 were the Account Executives. It was rare that I would 16 talk to people under the Account Executives. 17 Q. Well, let's then just look at a different email from 18 very much the same time, which may shed a little further 19 light, POL00060587. We can see that Mr Flemington seems 20 to have been at his kids' school sports day or something 21 but, if we go down, there's an email from him slightly 22 earlier in the day. So not a dissimilar time to the one 23 that we've just looked at from you, 13.16 on 1 July, and 24 you are copied in along with a crowd of people but also 25 including Jarnail Singh. 138 1 I just want to look at one particular bit, which is 2 actually over on the next page. This is "High level 3 points for the Board", and if we go to the bullet point 4 in the middle of the page with four blank bullet points 5 under it and there's the final one in square brackets, 6 which begins "One", so all I want to look at is that 7 one: 8 "One of the two defects has already been discussed 9 in a court case (Misra) -- being confirmed." 10 Now, we know that, in fact, it wasn't but what I'm 11 interested in is where that might have come from, where 12 that suggestion that it was raised in the Misra case 13 might have come from. Before I take you to anything 14 else, have you got any free memory of where that might 15 have come from? 16 A. I don't, I'm sorry. 17 Q. Well, then there's one other thing that I want to raise, 18 just to see if it jogs any memories. We have another 19 email chain -- and I don't need to take you to it but 20 I'll give the reference, it's POL00098797 -- and at 21 page 2 of that, it's clear that you and Mr Ismay had 22 been tasked together, on 28 June, so on the Friday, to 23 look into both the bugs. So do you remember that you 24 were working with Mr Ismay on that? 25 A. I've seen, in the bundle that I have, that there was 139 1 some emails which shows we were trying to find out more 2 information. 3 Q. Did Mr Ismay appear to you to have a reasonable 4 understanding about the receipts and payments mismatch 5 bug? 6 A. I can't remember. I can't remember if he did or didn't, 7 but I would be surprised if he didn't. 8 Q. Well, certainly, there's evidence that shows that he was 9 at that meeting that Ms Price took you to earlier, in 10 November 2010, when the three solutions were being 11 discussed -- 12 A. Yes. 13 Q. -- so that does tally up. We also know that he was 14 playing close attention to the Seema Misra trial. 15 Was it Mr Ismay who suggested that the receipts and 16 payments mismatch bug might have been revealed in the 17 Misra trial? 18 A. I don't know. I really don't know. 19 Q. What about Mr Singh? Did he say anything to you about 20 the Seema Misra trial or the receipts and payments 21 mismatch bug? 22 A. I don't believe I had any dealings with Mr Singh. 23 Q. You didn't? 24 A. No. 25 Q. You don't know him very well? 140 1 A. No. I know he's been copied on some emails but I didn't 2 have any dealings with him. 3 Q. So it wouldn't have been him who said anything like 4 that, at least not to you? 5 A. I can't -- not to me. 6 MS PAGE: All right. Well, thank you, Ms Sewell. Those are 7 my questions. 8 THE WITNESS: Thank you. 9 SIR WYN WILLIAMS: Thank you Ms Page. 10 Mr Moloney? 11 MR MOLONEY: Thank you, sir. 12 Questioned by MR MOLONEY 13 MR MOLONEY: Ms Sewell, you worked closely with Chris Aujard 14 on Project Zebra, the Deloitte report? 15 A. Yes. 16 Q. It appears that you were present at a morning meeting 17 with him, referred to in the email from Julie George 18 attaching the Zebra Action Summary that Ms Price has 19 recently asked you about? 20 A. Yes. 21 Q. Ms Price asked you about whether you informed Second 22 Sight about the ability of Fujitsu to delete 23 transactions in an undetectable way, and you said that 24 it would have been for Mr Aujard to inform Second Sight? 25 A. That's largely because there was -- as I've said, and 141 1 the Inquiry will know, there was a Project Sparrow set 2 up, and I was not part of that, so the line would've 3 been through -- 4 Q. A different stream -- 5 A. Yes. 6 Q. -- and it would have been Mr Aujard, rather than you? 7 A. Yes. 8 Q. When I asked questions of Mr Aujard, I asked him about 9 the Zebra Action Summary and the meeting you and he had 10 with Julie George and others, just as you've just been 11 asked by Ms Price. 12 A. Yes. 13 Q. I asked him whether or not he informed Second Sight 14 about the contents of the Deloitte report and the Zebra 15 Action Summary. He said, in response: 16 "The sense from those that were reviewing the 17 Deloitte report was not that this was a critical or 18 significant matter and I don't know why that is the 19 case. Clearly, the matter was considered and discussed 20 by numerous people internally. It could be -- and 21 I don't want to speculate but it could be -- that there 22 were no persons with the requisite access rights and 23 that was the reason or there could be other reasons for 24 it." 25 Now, I appreciate this is a difficult time for your 142 1 memory, your memory is not great around that time, but 2 do you remember you, or any of your department, saying 3 to Mr Aujard that there were no persons with the 4 requisite access? 5 A. No. 6 Q. Do you remember you or any of your department saying to 7 Mr Aujard that this was not a critical or significant 8 matter? 9 A. Not that I recall. 10 MR MOLONEY: Thank you very much. 11 SIR WYN WILLIAMS: Is that it, Ms Price? 12 MS PRICE: Yes, sir, it is. 13 SIR WYN WILLIAMS: Well, Ms Sewell, thank you very much for 14 making your witness statement and thank you very much 15 for coming to give evidence in person before the 16 Inquiry. I'm grateful to you for participating in that 17 way. 18 THE WITNESS: Thank you. 19 SIR WYN WILLIAMS: Right. So we'll adjourn until tomorrow 20 morning when we have Mr Cameron; is that correct? 21 MS PRICE: That's correct, sir. 22 SIR WYN WILLIAMS: Fine. 23 MS PRICE: Thank you. 24 (3.19 pm) 25 (The hearing adjourned until 9.45 am the following day) 143 I N D E X LESLEY JESSIE SEWELL (sworn) ..................1 Questioned by MS PRICE ........................1 Questioned by MS PAGE .......................125 Questioned by MR MOLONEY ....................141 144