1 Wednesday, 2 October 2024 2 (10.04 am) 3 MS PRICE: Good morning, sir, can you see and hear us? 4 SIR WYN WILLIAMS: Yes, thank you. 5 MS PRICE: Sir, before we proceed to call Mr Brocklesby, 6 there's just one short matter of evidence I wonder if 7 I might raise. 8 SIR WYN WILLIAMS: Yes. 9 MS PRICE: There are two short statements from witnesses who 10 will not be required to give oral evidence but which 11 relate to the evidence of Mr Staunton, and which I'd 12 like to read into the record, please. 13 SIR WYN WILLIAMS: Yes. 14 MS PRICE: The first is from Benjamin Tidswell, 15 a Non-Executive Director of Post Office Limited, and the 16 reference for that is WITN11290100. 17 The second is from Marianne Tutin, a barrister. The 18 reference is WITN11620100. 19 SIR WYN WILLIAMS: Thanks very much. 20 MS PRICE: Thank you, sir. With those documents read in, 21 may we please call Mr Brocklesby. 22 SIR WYN WILLIAMS: Of course. 23 CHRISTOPHER WILLIAM BROCKLESBY (affirmed) 24 Questioned by MS PRICE 25 MS PRICE: Can you confirm your full name please, 1 1 Mr Brocklesby? 2 A. Christopher William Brocklesby. 3 Q. Thank you for coming to the Inquiry to assist it in its 4 work. As you know, my name is Emma Price and I ask 5 questions on behalf of the Inquiry. 6 You should have in front of you a hard copy of 7 a statement provided by you to the Inquiry; do you have 8 that? 9 A. I do. 10 Q. It is dated 16 August this year. If you could turn 11 please to page 25, do you have a copy with a visible 12 signature? 13 A. I do. 14 Q. Is that your signature? 15 A. It is. 16 Q. Are the contents of that statement true to the best of 17 your knowledge and belief? 18 A. They are. 19 Q. That witness statement, for which the reference is 20 WITN11350100, is now in evidence and will be published 21 on the Inquiry's website in due course. 22 I'd like to start, please, with your professional 23 background and the role you held with the Post Office 24 until recently. As you set out in you statement, you 25 have a first class BSc in chemical engineering; is that 2 1 right? 2 A. That's correct. 3 Q. Upon graduating you embarked upon a career in IT? 4 A. Yes. 5 Q. That career has spanned 26 years to date? 6 A. Unfortunately, 36 years, I think! 7 Q. 36 years, forgive me. That is my error. And has 8 included Chief Information Officer roles for companies 9 including Tesco Bank, easyJet, Vodafone UK, and Dunelm; 10 is that right? 11 A. That's correct. 12 Q. Is it right that at Vodafone UK in particular, your IT 13 responsibilities included a large transformation 14 programme to consolidate multiple legacy systems? 15 A. That is correct, yes. 16 Q. Is it right that you joined the Post Office in August 17 2023 as Chief Transformation Officer? 18 A. Yes. 19 Q. You were in this role until 6 September this year? 20 A. Correct. 21 Q. Is it right that in this role you were a member of the 22 Strategic Executive Group responsible for IT, including 23 the delivery of the subpostmaster programme which is to 24 replace the Horizon system? 25 A. Yes. 3 1 Q. The new system intended to replace the Horizon system 2 will be known as the New Branch IT System; is that 3 correct? 4 A. That's correct. 5 Q. As CTO, you were accountable for the day-to-day 6 operation of Horizon from a Post Office perspective -- 7 A. Yes. 8 Q. -- although you say the service is still mostly 9 outsourced to Fujitsu? 10 A. That's correct. 11 Q. You explain at paragraph 9 of your statement that you 12 were also responsible for all change activities on the 13 Horizon system? 14 A. Yes. 15 Q. Could we have that paragraph on screen, please. It's 16 page 3 of WITN11350100. 17 So those change activities you list in this way: 18 "a) the regular Horizon software releases which 19 include defect fixes and enhancements for postmasters 20 "b) implementation of the Horizon Issues Judgment 21 recommendations and improvements 22 "c) infrastructure upgrades to reduce operational 23 risk (known as Datacentre Fortification), and 24 "d) projects to re-architect components of the 25 Horizon system to bring them into [Post Office Limited] 4 1 control and support." 2 Starting with (d), please, are the components being 3 brought under Post Office control and support those 4 which you identify at paragraph 8 of your statement, so 5 namely those which interface with third party partners, 6 such as banks and the Royal Mail Group. 7 A. That's correct, yes. 8 Q. Is it right that one of the reasons for this work was to 9 minimise the impact of migrating from Horizon to the new 10 system? 11 A. Yes. 12 Q. So it was progressing, was it, alongside the work to 13 delivery the New Branch IT System? 14 A. Correct. 15 Q. Turning, then, to (b), at the top of this page, and just 16 for the moment in terms of the parameters of your 17 responsibility in this area, what type of 18 recommendations and improvements arising from the 19 Horizon Issues judgment fell within your remit? 20 A. Most of the HIJ Remediation Programme, which had been 21 running for a number of years, had been completed by the 22 time I arrived at the Post Office. There was still 23 Phase 3 of that programme running but to call out 24 a couple of specific items that were left, there was 25 an improvement for postmasters called autostop rem in, 5 1 which was an improvement allow a much better process for 2 postmasters to accept stamps into their branches and 3 hence removing one of the causes of defects when those 4 stamps are booked in incorrectly. 5 And another was bringing the transactional database, 6 which is used for some data enquiries, under the -- 7 re-architecting it and bringing it under Post Office 8 control. 9 Q. You describe the team structure for Horizon work at the 10 Post Office at paragraph 10 of your statement. You had 11 a full-time IT Director reporting to you -- 12 A. Yes. 13 Q. -- Simon Oldnall -- 14 A. That's correct. 15 Q. -- who you say was responsible for all Horizon work at 16 the Post Office; is that right? 17 A. That's correct. 18 Q. He had a team of 45 people who managed the service 19 provided by Fujitsu through six different functions, 20 which you set out here in the paragraph (a) to (f); is 21 that right? 22 A. That's correct. 23 Q. To what extent were you involved in the actual work of 24 those functions, as opposed to Mr Oldnall reporting to 25 you on that work? 6 1 A. Most of the work was delegated to Simon Oldnall. I had 2 fortnightly one-to-ones with Simon to review the 3 progress of the work that was being undertaken on 4 Horizon but, as it was only one component of my 5 responsibilities, it was -- that was my main interaction 6 with the work. 7 Q. You address the monthly governance meeting between the 8 Post Office and Fujitsu at paragraph 12 of your 9 statement. These were led by Mr Oldnall from the Post 10 Office side and Dan Walton from the Fujitsu side; is 11 that right? 12 A. That's right. 13 Q. Did you attend those meetings? 14 A. Not as a matter of course. I did attend, I think, one 15 or two meetings when I first joined the Post Office, to 16 make sure I understood what was being discussed. 17 Q. Were there any times when you were requested to attend 18 those meetings for any specific issues? 19 A. I don't believe so, no. 20 Q. Did Mr Oldnall report back to you on key points from the 21 meetings? 22 A. Yes. 23 Q. That statement can come down now. Thank you. 24 Is it right that you joined the Post Office 25 Strategic Executive Group as soon as you started as 7 1 Chief Transformation Officer? 2 A. That's correct. 3 Q. You also became a member of the Improvement Delivery 4 Group, which you address at paragraph 22 of your 5 statement. Can we have that on screen, please, it's 6 page 7. You, say there that the group had the remit of: 7 "... addressing past failings, responding to current 8 issues, driving operation and cultural change and 9 rebuilding trust with postmasters. The committee 10 assessed progress on topics such as postmaster induction 11 and training, shortfall in discrepancies, suspensions 12 and terminations. It also assessed the progress of 13 addressing the [Horizon Issues judgment] findings within 14 Horizon. This gave me insight into the issues of the 15 past and the action plans to address those issues." 16 You say you were also the SEG sponsor for the HIJ 17 Remediation Programme, which had the remit of 18 implementing changes to the Horizon system in order to 19 address specific recommendations, and that was 20 a fortnightly meeting for that group chaired by the CEO. 21 You say there that this was: 22 "... a challenging environment in which [Post 23 Office] leaders were challenged on progress and pace." 24 Who was doing the challenging and who was being 25 challenged? 8 1 A. Each individual component that was being scrutinised was 2 led by a member of the leadership team and they 3 presented their progress. Most of the challenging was 4 coming from Nick Read, the Chief Executive. 5 Q. What was your impression when you took up the two roles 6 we've just looked at of progress which had been made by 7 the Post Office, in addressing specific recommendations 8 from the Horizon Issues judgment? 9 A. My impression was that the scope was very broad, clearly 10 a lot of individual topics that were being discussed, 11 and that lot of change was being made and had been made 12 to the way that Post Office operated, and that was 13 making a material difference. 14 Q. Can you recall an example of a point on which Post 15 Office leaders were challenged at meetings? 16 A. No, I can't. 17 Q. Although the remit of the Horizon Issues Judgment 18 Remediation Programme went wider, is it right that your 19 role was limited to ensuring the implementation of the 20 judgment in so far as it applied to the operation of 21 Horizon? 22 A. Correct. 23 Q. With that in mind, I'd like to ask you, please, about 24 some of the changes you deal with at paragraph 38 of 25 your statement. Could we go to that, please. It's 9 1 page 12. Focusing on the changes which are, on their 2 face, directly relevant to the operation of Horizon, and 3 starting with (e), you say: 4 "There is now much more support for postmasters with 5 discrepancies. This includes a 'Dispute button' which 6 postmasters use to relied that they need help and 7 a 3-tier support process to analyse and identify the 8 root cause of discrepancies. My team work with the 9 [Post Office] Retail to support Postmasters during these 10 investigations." 11 How does the Dispute button work? 12 A. My understanding is it's an opportunity for postmasters 13 to ask for help. So it is literally a part of the 14 Horizon application, which they can -- one they can 15 press and basically say, "I need help with what I -- 16 either my weekly or monthly reconciliation". 17 Q. Who is alerted to the need for help once the button is 18 used? 19 A. The Branch Support Team within the Retail area of Post 20 Office. 21 Q. Is that a Post Office support function? 22 A. Yes. 23 Q. How is the dispute resolved? 24 A. That's not an area directly within my remit, so I can't 25 give a lot of detail on the process that team go through 10 1 to resolve the discrepancies. 2 Q. You say at paragraph 6 of your statement that support is 3 largely outsourced to Fujitsu. Can you help, please, 4 with the three tiers and which aspects of that are held 5 by Post Office and which aspects are held by Fujitsu? 6 A. I believe all three tiers are held by Post Office, the 7 branch support team, the Network Support Team, which 8 I believe is a more expert function in terms of trying 9 to resolve discrepancies, and the third tier would 10 involve my team trying to work with the Retail team to 11 resolve anything that remains after those first two 12 investigations. 13 Q. In what sort of circumstances would your team be asked 14 to get involved? 15 A. When the root cause of a discrepancy hadn't been 16 discovered or understood by the previous two teams. 17 Q. How frequently, in the year you were there, were your 18 team called on in those circumstances? 19 A. I don't know. 20 Q. Are there any different helplines or lines of support 21 run by Fujitsu available to postmasters? 22 A. I don't believe so. 23 Q. I should ask first: is there a Post Office helpline that 24 is utilised as part of this support for subpostmasters? 25 A. Yes, the Branch Support Team. There's also -- for IT 11 1 issues, there is an IT Helpdesk that postmasters can 2 call. 3 Q. Are regular reports produced summarising the issues 4 being raised by postmasters on the helplines? 5 A. I understand they are included in the retail dashboard 6 which is something -- a report that is put together by 7 the Retail Team on a monthly basis and it goes to both 8 the Executive and the Board. 9 Q. How is that retail dashboard considered or analysed at 10 those levels? 11 A. I can't speak for the Board because I'm not a member of 12 the Board. At the Exec Team it's part of our monthly 13 agenda and it's open to scrutiny by the Executive Team 14 and they can ask any questions during that meeting. 15 Q. You say at paragraph 12(b) of your statement that: 16 "Defect reporting was a standing agenda item at the 17 monthly Post Office and Fujitsu governance meetings." 18 Does discussion of this topic at those meetings 19 include an analysis of the subpostmaster issues raised 20 with either Post Office or Fujitsu regarding software? 21 A. I'm not sure I understand the question. There is 22 a review of any new defects that have been raised -- 23 defects can be raised by either Post Office or 24 Fujitsu -- and a review of where there are changes to be 25 made as a consequence of that defect being raised, 12 1 a review of progress to resolve that defect. 2 Q. My question is really where the issue is raised by 3 a subpostmaster but it hasn't necessarily been reported 4 as a defect or recognised as such by Fujitsu or Post 5 Office. Is that something that would come to the table 6 to be discussed? 7 A. I don't believe so, no. 8 Q. Can you help at all with who is responsible for helpline 9 oversight; would that have been Mr Oldnall or someone 10 else? 11 A. So the Business Support Team has oversight from the 12 Retail function and the IT support line has oversight 13 from IT. I have a separate IT -- I did have a separate 14 IT Director, Mark Nash, who is responsible for the IT 15 Helpdesk. 16 Q. Looking again, please, at the changes you list at 17 paragraph 38 of your statement towards the bottom of 18 page 12, and this time at (h), you say there is: 19 "More openness on Horizon directs. Any defect with 20 a possibility of having financial impact to postmasters 21 is posted on Branch Hub (the postmaster communication 22 portal) and resolution is updated. This area is 23 something which sits directly within my remit. There is 24 also monthly SEG and Board reporting on Horizon 25 defects." 13 1 Dealing with the Hub, first of all, how do you 2 measure, if at all, subpostmaster engagement with the 3 Hub? 4 A. We have stats on a monthly basis, in terms of the number 5 of log-ins to Branch Hub, which has been consistently 6 going up since it was introduced. 7 Q. Are subpostmasters able to feed into the Branch Hub when 8 they have relevant experiences of problems with Horizon? 9 A. I believe that they can raise an incident on Branch Hub, 10 yes. 11 Q. Is the Branch Hub and the information on it looked at by 12 those involved in suspensions, terminations and recovery 13 of shortfalls, as far as you can say? 14 A. I am not aware of whether they look at that or not. 15 Q. Is any learning from the Hub used to inform the 16 development of the New Branch IT System? 17 A. I can't see an obvious correlation. I mean, in terms of 18 specific defects, yes, they are analysed to make sure 19 that clearly that they're not -- nothing equivalent to 20 them is included in the design of NBIT. So specifically 21 related to defects, yes. 22 Q. The statement can come down now. Thank you. 23 You refer in your statement to monthly Strategic 24 Executive Group and Board meetings reporting on Horizon 25 defects. Who provides the reports on this topic at SEG 14 1 and Board level? 2 A. Ultimately, it was myself that provided the information 3 from the Horizon team but I provided that into the -- 4 I would review it and then provide it to CoSec for the 5 inclusion in the SEG meetings. 6 Q. To what extent were these reports discussed or 7 challenged at SEG and board meetings? 8 A. Again, I wasn't a member of the Board meeting but I've 9 never been asked specifically, I don't believe, at 10 a board meeting. But, now and again, I would be asked 11 a question on the -- it wasn't just about defects. The 12 tech dashboard had a number of pieces of information in 13 terms of remote and privileged access, defects, number 14 of incidents, et cetera. So I would receive some 15 questions from fellow SEG members on a monthly basis. 16 Q. You say in your statement that there is nobody on the 17 Board with IT experience. How does this impact upon the 18 ability of the Board, critically, to assess reports on 19 Horizon defects, in your view? 20 A. I don't think it would -- on that specific topic, it 21 would have much impact because they, I'm sure, are able 22 to analyse a trend in terms of whether there was 23 a material increase in defects and/or -- or progress in 24 terms of resolving those defects based on the data that 25 they were presented on a monthly basis. So I don't 15 1 think, in terms of that aspect, that it would have had 2 an impact. 3 Q. What aspects did it have an impact on? 4 A. I think in terms of the broader discussions on 5 technology, specifically on progress, on projects and 6 programmes such as the SPM programme, which is 7 delivering the new NBIT application, it's quite 8 difficult to engage the Board in a detailed 9 conversation, and I think the consequences would 10 typically be -- and I refer to this in my statement -- 11 a risk aversion to how that progress is being made. 12 Q. When you say "risk aversion", how does that manifest? 13 A. Well, I think, whether it be Board or ARC, if you're not 14 familiar with systems development and IT programme 15 delivery, when it comes to topics, such as -- the 16 current status of NBIT is that it's been piloted in 17 a small number, I think five directly managed branches. 18 I think in a discussion as to progress and readiness, 19 people who are not used to the topic tend to want 20 a level of perfection that is actually detrimental to 21 the ultimate quality of the product because a beta 22 version of software or a pilot of software is there to 23 test the software in the real world and, by definition, 24 it won't be perfect. 25 It needs to be good enough but it won't be perfect 16 1 and that level of real-world experience means that the 2 ultimate end product would be of higher quality and 3 better for postmasters. So those types of topics are 4 difficult to engage in, if you've not been involved in 5 project delivery before. 6 Also, there's expert domain such as security, which 7 is a hot topic in any organisation, which relies on IT 8 systems, which, again, it's a technical topic. So 9 getting that balance -- the discussion as to how quickly 10 to remediate security issues, how much money to spend is 11 a difficult one to engage when people who are not 12 familiar with that topic. 13 Q. Given the history of the issues being investigated by 14 the Chair in this Inquiry, do you think there should be 15 someone on the Board with IT experience? 16 A. Yes, I think in other boards that I've interacted with, 17 that's been more and more of a theme, where there's been 18 a specific NED role which has been a digital or data 19 NED, that's been recruited to various boards. 20 Q. I'd like to turn, please, to the current Post Office 21 approach to the recovery of shortfalls. Could we have 22 on screen, please, paragraph 73 of Mr Brocklesby's 23 statement, that's page 22. At paragraph 73, you are 24 commenting on an article in The Times from February of 25 this year, and you say this: 17 1 "Specifically in relation to the suggestion that 2 'there is a prevailing culture that postmasters continue 3 to be "guilty"', this is, again, not a culture that 4 I recognise. For example, the way that discrepancies 5 are now handled by [Post Office] is unrecognisable from 6 the procedures of the past. Postmasters are given the 7 benefit of the doubt and unexplained losses are not 8 pursued by [Post Office Limited]." 9 With that in mind, I'd like to ask you, please, 10 about a document from July of this year. It's 11 POL00448520. Could we have that on screen, please. 12 These are the minutes of a Post Office Limited SEG 13 tactical meeting, dated 17 July 2024, which record you 14 having been in attendance. The minutes noted discussion 15 regarding branch discrepancies and loss recovery. Some 16 background is given, starting at the third sub-bullet 17 point down: 18 "By way of background, SEG noted that following the 19 recommendations made in the GLO and CIJ in 2018/19, 20 [Post Office Limited] had ceased action to recover 21 established losses from postmasters." 22 Then the next bullet down: 23 "This activity had been hold since this time, except 24 where a postmaster both agreed to repay the established 25 loss and proceeded to repay under a process established 18 1 in 2021 to identify and resolve discrepancies arising 2 mainly during trading period balancing; this process was 3 documented and regularly assured by the Assurance and 4 Complex Investigation Team." 5 The bullet under that: 6 "A key consideration was whether Horizon transaction 7 data might be a cause to of the discrepancy." 8 Then, going over the page, please, there is 9 an explanation of the thinking behind the voluntary 10 recovery/repayment process, and that's the third bullet 11 down. It says: 12 "The voluntary recovery/repayment process was 13 predicated on Horizon data being robust and that [Post 14 Office Limited] could rely on the data; [Post Office 15 Limited] was currently awaiting confirmation from both 16 [Post Office Limited] IT and Fujitsu and that this was 17 the case and this would be a key prerequisite to any 18 process that sought recovery in circumstances where the 19 postmaster did not voluntarily agree." 20 The minutes then record the SEG considering the 21 options for the process going forward: 22 "SEG considered the options ... and the associated 23 pros and cons. The options were to: 24 "Maintain the current situation. 25 "Maintain the current situation and communicate this 19 1 as a policy decision to postmasters. 2 "Cease all future recovery of losses. 3 "Seek recovery of established losses via a civil 4 means/deduction from remuneration, following an agreed, 5 defined process with an external review board that would 6 make the final recovery decision." 7 The prerequisites included the process involving an 8 external board, on this representative postmasters would 9 sit, and, towards the bottom of the page, the 10 penultimate line the prerequisites would include, 11 critically, "assurance on Horizon data"; do you see 12 that, highlighted there? 13 With your insight gained from your role in 14 implementing the recommendations of the Horizon Issues 15 judgment, do you think that Post Office's voluntary 16 recovery/repayment process should be predicated on 17 Horizon data being robust? 18 A. Yes, I do. 19 Q. Can you explain why? 20 A. Well, it provides the foundation for the -- for the 21 discussion and investigation around whether there's 22 a discrepancy and the size of that discrepancy. All of 23 that information comes from Horizon. 24 Q. The prerequisite for the proposed recovery plan was said 25 to be assurance on Horizon data. Is that referring to 20 1 a general assurance that Horizon data is reliable? 2 A. I believe so, yes. 3 Q. From whom was that being sought? 4 A. Specifically, Simon Oldnall. 5 Q. Was Simon Oldnall in a position to give that kind of 6 assurance? 7 A. Clearly, this is a topic that we've discussed around the 8 SEG table many times. I don't think any IT professional 9 can give a guaranteed assurance of the integrity of data 10 on any IT system, but what Simon can do -- and I think 11 this meeting particularly included a couple of new 12 members of the Executive Team that hadn't been 13 previously involved in discussions around discrepancies, 14 and were unaware of the work that had previously been 15 done around the HIJ Remediation Programme. 16 So what Simon was being asked to do was to restate 17 and remind SEG of all the work that had been done to 18 improve the Horizon system, to remove known defects and, 19 therefore, improve the quality of the underlying data. 20 Q. Given the history of Horizon issues and, in particular, 21 assurances given in the past that Horizon was robust in 22 a number of contexts, did you have any concerns about 23 this prerequisite or general assurance and what that 24 might lead to? 25 A. No, I didn't have any concerns about the data itself. 21 1 These conversations can be frustrating when some members 2 of SEG want an absolute guarantee provided by IT, 3 because I -- as I've just previously stated, it's very 4 difficult to provide an absolute guarantee, but to 5 assert all the work that's been done to improve the 6 situation, to assert the remaining defects that are 7 outstanding and how they don't impact postmasters 8 specifically, or only impact a small number of kind of 9 edge cases, and the fact that the system supports a very 10 large branch network, 7 million transactions a day, 11 which are concluded successfully. 12 Q. Did you agree that the correct way forward was to seek 13 recovery of established losses by civil means or 14 deduction from remuneration, with the prerequisites that 15 were set out in the minutes? 16 A. Yes, I did. I mean, I -- clearly within my role, I am 17 not responsible for the processes around those 18 investigations, discussions with postmasters, so I don't 19 have full insight in terms of the process of reviewing 20 discrepancies but, based on what I'd heard and the 21 confidence I had in Horizon, yes. 22 Q. What was your view on the alternative option that was 23 listed of a form of losses pool to which all postmasters 24 contributed, and from which repayments would be made? 25 A. Sorry, could you ask me that question again? 22 1 Q. Yes, well, we can look at it. So there was reference 2 underneath the bullet points we've just looked at: 3 "SEG discussed a number of other alternatives 4 including: 5 "Some form of 'losses' pool, to which all 6 postmasters contributed and from which repayments would 7 be made." 8 What was your view on that, as to whether that was 9 an appropriate recovery method? 10 A. Again, it's somewhat outside of my experience and 11 responsibilities but it appeared to me that that 12 wouldn't be a fair way forward in terms of all 13 postmasters contributing. There's obviously a range of 14 postmasters, their experience and the status of their 15 accounts. So it didn't feel as though that was a fair 16 way forward, to me. 17 Q. By the time you left the Post Office, what stage had 18 decision making reached on the way forward in terms of 19 loss recovery? 20 A. I don't believe this had come back to SEG for further 21 discussion. 22 Q. Had any assurance been given on Horizon data in general 23 terms by that point? 24 A. I'm not aware. There is a working group that was pulled 25 together -- Simon Oldnall was the IT representative on 23 1 that Working Group -- but I'm not aware of the progress 2 that was being made. 3 Q. Do you remain of the view that the way discrepancies are 4 now handled by the Post Office is unrecognisable from 5 the procedures of the past? 6 A. Yes, based on what I've heard reported at the Group 7 Executive, yes. 8 Q. That document can come down now. Thank you. 9 I'd like to ask you, please, about some clauses in 10 the subpostmaster contract, as amended in August 2020. 11 Could we have that on screen, please. It's POL00000254. 12 It's page 32, please. We can see, towards the bottom of 13 the page, there are Post Office duties, and this is 14 towards the bottom of page 32, please. If we can go 15 over the page, please. Just towards the bottom there. 16 Thank you. 17 So this section deals with Post Office duties and, 18 going over the page, please, starting at clause 20.3, 19 this duty is set out: 20 "Properly and accurately effect, record, maintain 21 and keep records of all transactions effected using 22 Horizon ..." 23 Does a mechanism exist for monitoring the 24 identification of, and payment of, shortfalls by 25 subpostmasters? So I'm not asking you about the 24 1 interpretation of this clause but, just in terms of what 2 this promises to do, is there a mechanism for monitoring 3 the identification of, and payment of, shortfalls by 4 postmasters? 5 A. I'm not aware of that level of detail. 6 Q. Just looking the next two clauses: 7 "Properly and accurately produce all relevant 8 records and/or explain all relevant transactions and/or 9 any alleged or apparent shortfalls attributed to the 10 Subpostmaster ..." 11 Then 20.5: 12 "Cooperate in seeking to identify the possible or 13 likely causes of any apparent or alleged shortfalls 14 and/or whether or not there was indeed any shortfall at 15 all ..." 16 Is the reason for all shortfalls, as a matter of 17 practice, identified by the Post Office? 18 A. Is your question is every single shortfall that's 19 experienced from a postmaster -- 20 Q. Well, starting with any that have been raised, that in 21 issue. 22 A. Again, this is something that is the responsibility of 23 the Business Support Team, rather than IT, but my 24 understanding is not every shortfall is -- has a root 25 cause. 25 1 Q. That document can come down now. Thank you. 2 Moving, please, to the role played currently by the 3 Post Office in prosecutions. Between May and July of 4 this year, the CEOs of Post Office Limited and Fujitsu 5 exchanged correspondence regarding the conduct of Post 6 Office's investigations function. I think you've had 7 that correspondence sent to you by the Inquiry; is that 8 right? 9 A. That's correct. 10 Q. You've had a chance to review that? Could we have on 11 screen, please, FUJ00243204. This is a letter from Paul 12 Patterson to Nick Read, dated 8 July 2024, seeking to 13 bring to Mr Read's attention concerns concerning conduct 14 exhibited by members of Post Office Limited. The second 15 paragraph says this: 16 "I am glad that we both share a commitment to learn 17 lessons from the Post Office Horizon scandal and to 18 ensure that the appalling treatment of postmasters, and 19 the miscarriages of justice that occurred, could never 20 happen again. That was the reason for my writing to 21 you. I was seeking to bring your attention concerning 22 conduct exhibited by members of your organisation. 23 "In simple terms, the Post Office is requesting that 24 [Fujitsu Services Limited] give expert opinion evidence 25 to be used in criminal proceedings against postmasters 26 1 and post office workers." 2 Enclosed to Mr Patterson's letter is an email chain 3 between Simon Oldnall, so your direct report, John 4 Bartlett and Fujitsu, dated between 11 April and 1 May. 5 Could we have that on screen, please. It's FUJ00243158. 6 Starting on page 4, please, on 11 April, Mr Oldnall 7 emailed Daniel Walton of Fujitsu, saying: 8 "Dan 9 "I understand from John that there have been some 10 challenges with supporting an ongoing police 11 investigation that involves a large sum of money. 12 "I obviously understand broader context, but wanted 13 reassure [sic] that [Post Office Limited] is supporting 14 the police investigation and offering any and all 15 assistance we can. Can I ask that you help with any 16 conversation that City of London Police need to have 17 with Fujitsu Services Limited." 18 Then on 19 April, Mr Bartlett replied in the chain. 19 That's page 2, please. Scrolling down, please. The 20 third paragraph down: 21 "As the potential victim in this case, [Post Office 22 Limited] would be grateful if you can provide me with 23 contact details for either the equivalent person in 24 Fujitsu (in the UK) to my role (ie in overall charge of 25 investigations, or perhaps the Head of Security if you 27 1 do not have a dedicated Investigation Team) or 2 an appropriate person in your UK Legal Team. I will 3 then pass those details on to [City of London Police] 4 who are looking to have a trilateral conversation with 5 Fujitsu, [Post Office Limited] and [City of London 6 Police]. 7 "It is impossible to overstate how important this 8 is: I need to advise both the police and [Post Office 9 Limited] as to the evidentially-established reliability 10 (or not) of data that is being used every day in 11 establishing outcomes with postmasters and, potentially, 12 to be presented to the criminal justice system by the 13 police and the three public prosecuting agencies. The 14 non-provision of relevant witness statements from [Post 15 Office Limited] and Fujitsu will rightly be interpreted 16 by the police and prosecutors as [Post Office Limited] 17 and Fujitsu not having faith in the reliability of the 18 data with the obvious outcome resulting." 19 That document can come down now. Thank you. 20 Simon Oldnall reported to you. Before it was sent 21 to you by the Inquiry were you aware of this 22 correspondence? 23 A. No. 24 Q. If you had seen it at the time you were in your role, 25 would it have concerned you? 28 1 A. Yes. I mean, there are politics at play, clearly, in 2 terms of people being careful about what they said and 3 did with regards to Horizon. But, yeah, it would have 4 concerned me if Fujitsu were not able to provide some 5 level of assurance, although I understood, as I said, 6 that there are politics at play here, so they may not 7 want to be providing that level of detail and assurance 8 to law enforcement. 9 Q. Would it have concerned you that it was being requested 10 by Post Office, that is, Fujitsu were being asked to 11 give, in essence, expert evidence as to the reliability 12 of a system with the history that this has? 13 A. It was probably naive to get involved but I think, you 14 know, with the best of intent, people were trying to 15 help the police force in their investigations. So, with 16 hindsight, probably should have let the police get on 17 with it with Fujitsu. 18 Q. Were you aware at the time of Mr Oldnall's role in 19 assisting the police with ongoing prosecutions of 20 subpostmasters? 21 A. No, not specifically. 22 Q. Do you think you should have been aware of that aspect 23 of Mr Oldnall's work? 24 A. From what I understand from the email conversation, this 25 is one specific, significant case that the Met Police 29 1 were pursuing. I don't think -- I'm comfortable that 2 Simon didn't feel it was necessary to raise this with 3 me. 4 Q. I'd like to move, please, to progress on the New Branch 5 IT System. The Inquiry has received evidence that, 6 although it was initially proposed that the New Branch 7 IT System would be rolled out to enable the Post Office 8 to exit its contract with Fujitsu for Horizon Support 9 services by March 2025, delays in the development in 10 rollout of the system have meant that the proposed start 11 date for deployment of the system is now June 2026. 12 Does that accord with your understanding at the point 13 you left the Post Office? 14 A. That's correct, yes. 15 Q. Could we have on screen, please, BEIS0000776. These are 16 the minutes of a UKGI Post Office Limited quarterly 17 shareholder meeting, dated 14 September 2023. You were 18 in attendance and are abbreviated to "CB" in the 19 minutes. Going to page 4, please. Under item 5, 20 "NBIT", so that's the New Branch IT System, isn't it? 21 A. Yes. 22 Q. The fifth bullet point there: 23 "CC asked about negotiations with Fujitsu. CB ..." 24 So is that you -- is that a reference to you, the 25 initials "CB" there? 30 1 A. Yes. 2 Q. "... outlined current arrangements with Fujitsu: support 3 runs to March '25 while infrastructure expires in March 4 '24. A request to extent infrastructure to March '25 5 will come to the October Board. The procurement 6 strategy beyond March '25 will kick off early next year 7 to extend those two contracts. To date [Post Office 8 Limited] has told Fujitsu that they would like 9 a flexible agreement going forward without a precise end 10 date, but Fujitsu would like to see a funded and 11 well-planned SPMP so they know [Post Office Limited] is 12 serious about replacement. In short Fujitsu is happy to 13 collaborate if they know [Post Office Limited] is 14 working to get out." 15 Just keeping that in mind, could we have on screen, 16 please, FUJ00243299. This is a letter from Fujitsu to 17 you, dated 15 December 2023, and it refers to a request 18 from Post Office Limited in November 2023 to extend the 19 Horizon contract. Fujitsu explains the various 20 challenges to the feasibility of the continued delivery 21 of the Horizon system and associated services. 22 There was then a further letter on 3 July this year, 23 from Fujitsu to Mr Oldnall. Could we have that on 24 screen, please. It's FUJ00243301. Starting at the 25 third paragraph down, please. There is this: 31 1 "We have seen limited formal engagement from [Post 2 Office Limited] to meaningfully progress the planning of 3 exit at the Exit Date. Post Office is instead focused 4 on seeking to secure an extension and planning for exit 5 to occur before the end of extended contract term." 6 Then underneath: 7 "The purpose of this letter is to escalate the 8 position so that [Post Office Limited] engages 9 proactively with [Fujitsu] to plan and prepare for [Post 10 Office Limited] to take over the services that [Fujitsu] 11 is due to cease providing on the Exit Date. As 12 discussed, [Post Office Limited] needs to assign an Exit 13 Manager to prepare with [Fujitsu] an exit plan." 14 Forgive me for going through that in some detail but 15 it sets out a little the chronology of the piece. 16 A. Yes. 17 Q. What was the status of the development of the 18 replacement for the Horizon system on your departure 19 from Post Office? 20 A. So we had developed some software that was live in five 21 branches supporting a subset of postmaster transactions, 22 a pilot of the ultimate end software. There was still 23 a lot of software to be built and, hence, a two-year 24 timescale, just under two-year timescale, to build out 25 a full solution, that is not only across all of the 32 1 transactions but includes a system that's performance 2 secure, et cetera. 3 But the fact that there was pilot software running 4 in a branch used to serve real customers was a great 5 start, but a long way to go in terms of the ultimate end 6 goal of retiring Horizon. 7 Q. Do you think that the Post Office had in place 8 a realistic plan for delivery of a replacement system on 9 your arrival? 10 A. On my arrival? 11 Q. Mm. 12 A. No. 13 Q. Can you elaborate as to why you say that's the case? 14 A. On my arrival, the plan of record was that NBIT would be 15 delivered and fully deployed by March 2025, and there 16 was a lot of assumptions included in, yes, the Fujitsu 17 relationship, other procurement deals, et cetera, that 18 were built on the back of a March 2025 assumption. But 19 clearly, based on what I could see when I arrived, 20 namely there was little to no software that had been 21 delivered to date, that the software that had been built 22 had a lot of work still to be done in terms of defects, 23 an awful lot of work in terms of things like security, 24 and, given the fact that there was a plan to deploy that 25 software to 11,700 branches that would have taken two to 33 1 two and a half years, if you work back from March '25 2 and if it takes two to two and a half years to deploy 3 the software, then the software needs to have been ready 4 by the time -- at the time when I arrived, and it 5 clearly was not even close to being ready. 6 So no, there was no credible plan to deliver a March 7 '25 outcome. 8 Q. Did you encounter any challenges in delivering the 9 replacement to Horizon programme? 10 A. I'm not sure I understand the question. It's a complex, 11 difficult programme to deliver. So it's -- 12 Q. Breaking it down as to what those challenges might have 13 been, or starting from this position: did you put in 14 place a plan for delivery of the replacement system on 15 your arrival? 16 A. Yes, there was a lot to do. I think, as we've heard 17 from previous witnesses, there wasn't one programme; 18 there were two programmes: one that was building the 19 software; and another programme that was looking at how 20 to train postmasters to deploy the software into branch. 21 That wasn't a credible and realistic set-up because the 22 two programmes weren't interacting, talking, 23 communicating and there was no integrated plan. 24 The leadership of both of those programmes had left 25 the Post Office, so there was a vacuum in terms of 34 1 credible leadership and governance. There was lots of 2 issues in terms of the quality of the software that had 3 been produced to date. So there was lots to do. 4 This was a remediation, this was a complete 5 rebaselining of the programme plan. This was 6 a restructuring of the team. This was removing 70 per 7 cent of the people that are on the programme in order to 8 regain control. So, as part of that, there was a lot of 9 remediation work to do but, in early 2024, we did then 10 start to build out a new plan based on an understanding 11 of where the programme was at that stage, which was the 12 plan that you previously referred to, which has the 13 software being built, tested, in real life, with 14 postmasters, and ready to be deployed by the middle of 15 2026 and, ultimately, all postmasters and all branches 16 being online by the end of 2028. 17 Q. That plan, having been put in place in early 2024, did 18 you find any obstacles in relation to that plan, either 19 because of issues with the governance of Post Office or 20 otherwise? 21 A. Look, these things are hard to deliver, and that was 22 always going to be my expectation that there would be 23 issues along the way. It's never going to be an easy 24 ride. I think we had subsequent reviews of the 25 programme. I think governance was an issue, in terms of 35 1 too much governance. There are a lot of stakeholders at 2 Post Office, so getting quick decisions made at the 3 right level is always a challenge. I've already 4 referred to risk aversion, which is difficult when 5 you're trying to take considered risks as part of the 6 development and ongoing deployment of the software. And 7 just finding out more issues from the past, which have 8 to be remediated, along the way. 9 So yes, there continually things that we needed to 10 address as part -- and they will continue, in order for 11 the programme to be successful. 12 The other thing, I think, is the ongoing funding of 13 the programme, which is very incremental, and so, you 14 know, there's always a sense that the programme is 15 funded for another few months, and then there's a lot of 16 work to be done to get another piece of funding through 17 from DBT, and ultimately HM Treasury. That is a 18 very difficult way to progress, when you're trying to 19 motivate people for a two, three-year journey, when 20 people know that we're only really formally funded for 21 another few months, and then who knows what might 22 happen? 23 Q. Were you aware of the challenges to the feasibility of 24 the continued delivery of Horizon, which was referenced 25 in the Fujitsu letter of 15 December, that we looked at 36 1 when looking at that -- 2 A. Yes. 3 Q. -- chain of correspondence? 4 A. Yes. 5 Q. Were you aware of that at the time? 6 A. Yes. 7 Q. Was the Post Office Board aware of that at the time? 8 A. Yes. 9 Q. Was it right that, at that point, the Post Office had 10 not assigned an Exit Manager to prepare an exit plan 11 with Fujitsu? So you will recall the later letter. 12 A. That is correct but Fujitsu were aware, and had been 13 aware for some time, that we needed an extension. There 14 was no option but to extend Fujitsu Services because 15 NBIT wasn't ready. So, you know, we had been working 16 with them on the ground at that stage for many months, 17 working through what an extension would look like at 18 a very detailed level, in terms of working through all 19 the contract schedules and some of the terms and 20 conditions. So they knew that we were going to be 21 asking for an extension, and those were ongoing 22 conversations. 23 So it was kind of, again, seen as slight game 24 playing by Fujitsu to ask for an Exit Manager when they 25 were very clear that there wouldn't be an exit in March 37 1 '25. 2 Q. Were there any risks, from an IT perspective, arising 3 from Horizon's end of service live status? 4 A. Yes, there are risks of having infrastructure that is 5 out of support or nearing, in terms of resilience, in 6 terms of the risk of failure. There had been 7 a programme called "Datacentre fortification", which had 8 spent a lot of money previously, and was, during my 9 tenure, continuing to spend money to improve the 10 standard of the infrastructure, to upgrade many 11 components, but there were still specific components 12 that needed further investment. 13 That investment was understood, had been worked 14 through with Fujitsu in terms of the cost -- potential 15 costs and timescales, and all of those costs were 16 included in the business case that we put forward to 17 Treasury. 18 So, alongside the costs for the delivery of NBIT, we 19 were also asking for investment in the Horizon 20 infrastructure in line with the risks and the 21 requirements of Fujitsu, as they had identified. 22 Q. Was investment related to or to mitigate those risks 23 forthcoming? 24 A. Yes, I mean, the conversations -- when we had approvals 25 during my tenure, they included all the components that 38 1 we sought and that included Fujitsu infrastructure. The 2 reason I hesitated was, of course, ultimately, because 3 of this incremental nature of funding, not all of the 4 investment that we were required, to mitigate those 5 risks was ultimately -- you know, this is an ongoing 6 process over discussions and incrementality. So it was 7 included in the approvals that we had been given to date 8 but, ultimately, that wouldn't have funded full risk 9 mitigation because there are future business cases that 10 need to be approved to address those risks. 11 Q. Moving, please, to Project Willow. Is it right that 12 Project Willow relates to concerns which were raised 13 about the New Branch IT System? 14 A. Yes. 15 Q. The Inquiry understands that there are three strands to 16 the investigation; is that your understanding? 17 A. I've only been aware of Willow2 and Willow3, I'm not 18 aware of what Willow1 was. 19 Q. But there were three parts to it? 20 A. Yes, that was my understanding. 21 Q. Could we have on screen, please, POL00448907. This is 22 an ad hoc A&CI Team report prepared by John Bartlett for 23 the Board in August 2024. This is a document that 24 you've only seen very recently and, is it right, that 25 you've only seen this for the first time this morning? 39 1 A. Correct. 2 Q. We'll take this as slowly as we need to and, if you need 3 any time to consider the text that I'm asking to look 4 at, please do say? 5 A. Thank you. 6 Q. Could we go, please, to page 6. This provides the 7 background to Willow2. It says: 8 "Multiple sources of information indicated that 9 there were potentially two heads of alleged concerns 10 relating to the NBIT teams: 11 "That information provided to GE and the CEO was 12 presented in a skewed manner to prompt certain outcomes 13 and so past decision making was flawed; and 14 "[Secondly] That infosec elements of design and 15 testing were 'turned off' due to pressure from 16 contractors on those responsible for infosec in order to 17 improve the speed of progression irrespective of the 18 long-term impact on the reliability of the system." 19 So just taking those two parts in turn, is that 20 an accurate description of the first aspect of concern: 21 that information provided to GE and the CEO was 22 presented in a skewed manner, so past decision making 23 was flawed; is that an accurate summary of what the 24 concern was? 25 A. Yes. 40 1 Q. What can you tell us about the circumstances in which 2 that concern was raised and the response to it? 3 A. I was led to believe it was a whistleblower allegation. 4 I know no more detail than that. 5 Q. In relation to the second aspect of this, was that 6 raised in the same way; was that part of the same 7 concern? 8 A. I don't know. 9 Q. Okay. Can you help, please, with what this concern 10 might have been referring to, specifically in relation 11 to turning off of some aspects of the design and testing 12 to improve the speed of progression? 13 A. Yes. So when you're developing software, there is 14 obviously aspects of the software that can be seen and 15 can be demonstrated, ie the screens that a postmaster 16 would use to serve a customer. So they can be 17 demonstrated to postmasters, to whomever would like to 18 see them. But, in order to provide a fully resilient 19 piece of software that is fit for purpose to deploy to 20 a very large retail network, there are a lot of unseen 21 requirements. Those would be things like security; 22 performance, that it can not just work on one computer 23 but indeed works on 25,000 counters; that it can be 24 monitored so that the IT Team know when it's working and 25 when it isn't. So there are what would be called 41 1 non-functional requirements that are behind the scene 2 that are a very important part of delivering a full 3 software solution. 4 Q. Can you help, please, with what aspect of the 5 reliability of the system the concern related to; what 6 was the concern about the impact? 7 A. Well, software, both the developed software and 8 software -- the party software that is used has -- can 9 have -- vulnerabilities, ie weaknesses that could be 10 exploited in order to initiate some kind of cyber attack 11 on the Post Office. So it's important that those 12 vulnerabilities are understood, and they are addressed 13 before the software is rolled out to a material number 14 of postmasters and is relied upon by Post Office, or 15 else clearly there is an inherent risk of cyber threat. 16 Q. So the risk here, you're saying, is one of cyber threat? 17 A. Yes. 18 Q. Is there anything about that reference to the 19 reliability of the system and the concern that was being 20 raised that was relevant to accounting discrepancies or 21 their potential? 22 A. No, I don't believe so, no. 23 Q. In terms of what was done about the concerns that were 24 raised, it appears from the bullet below Pinsents and 25 Grant Thornton were engaged to independently 42 1 investigate; is that what happened? 2 A. Yes, that's my understanding. Grant -- Grant Thornton, 3 I recognise. Pinsents, I do not. 4 Q. Do you know what stage investigation had got to by the 5 point at which you left the Post Office? 6 A. No, and I think I need to point out that the bullet 7 point underneath suggests that I had SEG oversight of 8 this investigation. That wasn't my understanding. So 9 I certainly didn't -- I was aware of the investigation, 10 I was interviewed by Grant Thornton as part of the 11 investigation, but I certainly wasn't aware that I was 12 the SEG owner. I certainly didn't receive any status 13 reports. I see in the document later on that there are 14 issues with Grant Thornton and their engagement. 15 I wasn't aware of that. 16 So on a number of occasions I would ask HR 17 specifically what the status was and when it was due to 18 complete, and was told that investigations were ongoing. 19 So I don't recognise the statement that I had oversight 20 in some way for the investigation, and I'm not sure it 21 would have been appropriate. 22 Q. We'll come on to what may have been being referred to 23 here in terms of you being conflicted. We'll come back 24 to that point but I just want to deal, first of all, 25 with the substance of what was being said in that 43 1 concern dealt with under background. Do you consider 2 that past decision making had been flawed because of the 3 way that evidence or information had been presented? 4 A. I don't have specific reports in mind where I know for 5 sure that there's a report to a Board or any other 6 governance meeting where the reporting was overly 7 positive or incorrect, or ignoring of issues with the 8 programme. However, as I already stated, the fact that 9 the programme was continuing to report progress against 10 a March 2025 date in early 2023 wasn't credible, in my 11 mind, and therefore I can imagine that must have been 12 the case but I don't have access to specific reports 13 that would confirm that. 14 Q. Going, please, to page 8 of this document, this deals 15 with Willow3, so the third limb of it, and it sets out 16 the background in this way: 17 "A&CI were asked to investigate an allegation that: 18 "During a briefing to the Board on alternatives to 19 the in-house built NBIT, that Chris Brocklesby allegedly 20 misrepresented a possible alternative offered by 21 a company called Escher; and 22 "The true extent and completeness of the bid/offer 23 by Escher to [Post Office Limited] was incorrectly 24 discounted and suppressed as a viable alternative 25 without broader consideration." 44 1 Was this concern that had been raised discussed with 2 you before you left Post Office? 3 A. Yes, it was. 4 Q. Who discussed it with you? 5 A. The third party that was investigating: Grant Thornton. 6 Q. Did you misrepresent an alternative proposal to the 7 Board? 8 A. No, I didn't. 9 Q. Has an independent external investigator been engaged to 10 support that Willow3 investigation; is that the company 11 you were just referring to? 12 A. Yes. 13 Q. Do you know when it is anticipated to conclude its 14 investigation? 15 A. No, I do not, no. 16 MS PRICE: That document can come down now. Thank you. 17 Sir, I have reached the end of a topic and I am 18 about to turn to another. Would that be a convenient 19 moment for the morning break, please? 20 SIR WYN WILLIAMS: Certainly, yes. 21 MS PRICE: If we could have 15 minutes, I think that takes 22 us to 11.35. 23 SIR WYN WILLIAMS: Certainly, fine. 24 MS PRICE: Thank you, sir. 25 (11.21 am) 45 1 (A short break) 2 (11.36 am) 3 MS PRICE: Good morning, sir. Can you still see and hear 4 us? 5 SIR WYN WILLIAMS: Yes, thank you. 6 MS PRICE: Mr Brocklesby, I'd like to come next, please, to 7 Project Phoenix and to Past Roles. Could we have on 8 screen, please, POL00448864. These are the minutes of 9 an SEG meeting which took place in March 2024, which you 10 attended. 11 Going to page 3, please. Under the heading "3.1 12 Past Roles", there is this at the first two bullet 13 points: 14 "SR and NM spoke to the paper which set out 15 a recommendation on the approach to be taken in relation 16 to the Past Roles Review and staffing in the RU in the 17 light of the change in operational context and political 18 environment. 19 "As a reminder, the Past Roles Review had been 20 commissioned to look at the roles and activities of 21 current employees who may have previously undertaken 22 a role related to the subject of the POHIT Inquiry, to 23 examine whether any conflicts, or perception of 24 conflict, arose." 25 Did the Past Roles Review arise out of the Project 46 1 Phoenix work? 2 A. No, I don't believe so. I believe they were happening 3 in parallel. They were a separate scope. 4 Q. Were you involved in the Past Roles work, which was 5 happening and is referred to here? 6 A. No. 7 Q. Having been present at this meeting, what was your 8 understanding of what the change in operational context 9 and political environment, referred to in the first 10 bullet point, was a reference to? 11 A. I think this referred to the fact that this had been 12 highlighted in the press and/or raised as an issue at 13 Board meetings that there were still members of Post 14 Office, particularly those in the RU, that had 15 previously been involved in postmaster investigations. 16 Q. Were it not for the change in operational context at 17 political environment, would this work have been 18 progressed? 19 A. It's difficult for me to say, as I really wasn't 20 involved in the RU or discussions around those roles. 21 Q. There was a vote on how to proceed recorded on page 4, 22 over the page, please. About halfway down the page, the 23 penultimate bullet point there: 24 "The SEG discussed the difficult trade-offs at play, 25 with the majority voting for the 'many to few' 47 1 recommendation. The inevitability of delays to redress 2 claim processing times was not, however, accepted and 3 SEG noted a number of different resourcing approaches 4 and models, including those adopted in other industries, 5 such as insurance and claims processing." 6 Then there's a footnote at the bottom of the page, 7 please, which says this: 8 "NR, CB and KS ..." 9 Was "CB" a reference to you? 10 A. Yes, it was. 11 Q. "... voted for Option 3, 'many to few'; OW voted for 12 Option 2, 'no further action', KMcE abstained on the 13 basis Option 3 had the majority vote." 14 Then it goes on to give another reference to 15 non-voting members, noting they supported Option 2. 16 You voted for the "many to few" option, over no 17 further action; what did this mean? 18 A. It meant that those members -- we'd seek to redeploy 19 those members of the RU team that were in scope, 20 ie I think there was a reference to red roles, ie those 21 people that were in the RU that had been involved in 22 previous investigation work. 23 Q. Just pausing there, RU, that's the remediation work, is 24 it? 25 A. Remediation Unit, yes. 48 1 Q. Okay. Please continue. 2 A. Pardon? 3 Q. I didn't mean to interrupt, just to clarify that? 4 A. No, I think I was done. That's what it was. It was 5 considered to be -- considering the pressure to make 6 sure that there was no conflict of interest, that, even 7 though there was no implication that there was any 8 wrongdoing on behalf of those individuals, it was -- the 9 best outcome for both Post Office but also for the 10 individuals concerned, was that they were, as it were, 11 taken out the firing line and there were other roles 12 sought for them elsewhere in Post Office. 13 Q. Could we have on screen, please, paragraph 32 of 14 Mr Brocklesby's statement. That's page 10. At 15 paragraph 32, you say that: 16 "... my observation is that the culture has been 17 significantly influenced by the historic issues being 18 addressed by the Horizon Inquiry which has resulted in 19 risk aversion and a tendency to defer decisions to 20 senior management." 21 That risk aversion you've already referred to. You 22 go on at paragraph 33 to say: 23 "I would say that there is a positive culture of 24 constructive challenge with a good level of constructive 25 challenge in the organisation." 49 1 With that in mind, I'd like to go, please, to 2 an email from Owen Woodley to the Post Office Board from 3 February this year, which you were copied into. Could 4 we have on screen, please, POL00448309, page 2, please. 5 Scrolling down a bit, please. This email here of 6 9 February 2024 from Owen Woodley forwarded on an email 7 from Elliot Jacobs, and we see that over the next page, 8 please, page 4 -- two pages on, forgive me. That email 9 is there from Elliot Jacobs, also 9 February, to Nick 10 Read and others. In this email there is frustration 11 expressed about the progress of Project Phoenix. 12 It's right, isn't it, that Project Phoenix is 13 a review of all historical investigations where 14 allegations have been made by postmasters of wrongdoing 15 on the part of the Post Office or Post Office employees, 16 as part of the Human Impact Hearings for the Inquiry. 17 A. That's correct. 18 Q. Mr Jacobs started his email in this way: 19 "Following on from our meeting almost 2 weeks ago 20 where I expressed in the strongest of terms my 21 frustration and utter disbelief that the matter of 22 Project Phoenix was still nowhere resolved I am 23 concerned we have not received any update on the 24 activity since." 25 Then the third paragraph of his email says this: 50 1 "The claim that this is 'difficult' will simply not 2 cut it. If it was easy someone might that have done it 3 by now; but it is the fact that it is hard that we must 4 grasp the nettle and get it done. It is both optically 5 and morally wrong that this has not been dealt with 6 before. This not a 'witch hunt' (as it has been 7 advertiser by light previously) -- this is about making 8 certain the culture and frankly the future of this 9 business is not mired in the wrongdoing of bad people 10 who did truly awful things, some of whom -- to this very 11 day -- believe they did the right thing!" 12 There is a further email in this email chain after 13 the email forwarding this one, on 10 February, and 14 that's on page 1. In the third paragraph here he says: 15 "It does however seem odd that not a single one is 16 suspended whilst this is ongoing? Why is that? We seem 17 to suspend people on a rejected basis when 18 investigations are ongoing? Why not on this matter?" 19 First of all, can you help with who is now 20 responsible for oversight of the Investigations Team? 21 If you can't help, just say. 22 A. No, I don't know, I'm afraid. 23 Q. Can you help with why you were a copied recipient of the 24 email chain we've just looked at? 25 A. Because I was the Chair of the Project Phoenix Panel. 51 1 Q. Do you share Mr Jacobs' view as expressed about the pace 2 and the nature of decision making on Project Phoenix? 3 A. No, I don't. 4 Q. Why not? 5 A. Given the scope of the panel, which, to recap, was to 6 review investigations that had been conducted into 7 approximately -- on approximately 50 cases and make 8 a decision as to what action to take, namely to -- that 9 there is no further action, or more investigative work 10 is required, or indeed to pass that case or those 11 individuals to the HR team for a misconduct 12 investigation. 13 There were 50 cases to get through. We prioritised 14 the 20 or so cases that referred to current members of 15 staff. But each case needed to be investigated by 16 a qualified investigator, required going through old 17 material, finding the recordings of previous interviews 18 with postmasters, offering postmasters the opportunity 19 to be interviewed again, specifically by those case 20 reviewers, and to come up with recommendations in each 21 case. 22 Given that quantity of work and the limited number 23 of investigators, it wasn't clear how we could go any 24 faster. We took the role very seriously. We, the 25 panel, was available immediately when cases had been 52 1 completed and we quickly made decisions on everything 2 that was put before us. But it wasn't clear how we 3 could go any faster, given the workload. 4 Q. Who, within the Post Office, had referred to Project 5 Phoenix as a "witch hunt"? 6 A. I'm not aware. 7 Q. Is that how Project Phoenix was viewed by some employees 8 within the Post Office? 9 A. I don't think many people were aware of what Project 10 Phoenix was, so I can't answer that question. I think 11 it was a small number of people that were even aware 12 that this was ongoing. 13 SIR WYN WILLIAMS: Over what period of time, approximately, 14 were you chairing this panel, Mr Brocklesby? 15 A. From memory, Sir Wyn, the panel started at the beginning 16 of 2024, so January or February, through to my departure 17 on 6 September. 18 SIR WYN WILLIAMS: So it was still functioning in its role 19 in September, and we're looking at Mr Jacobs' email in 20 February, yes? 21 A. That's correct, sir. 22 SIR WYN WILLIAMS: Yes. 23 A. It's coming to -- it is very close to the end. I think 24 a number -- the conclusions have been drawn on, 25 I believe now, all seven current members of staff and 53 1 the kind of thematic review document has also been 2 produced in terms of lessons learnt through the -- as 3 a consequence of all of the investigations. So I expect 4 it to be closing soon. 5 SIR WYN WILLIAMS: On the face of it -- well, not on the 6 face of it. Can you explain to me, you know, in 7 summary, why you were thought appropriate to chair this 8 panel? 9 A. Um -- 10 SIR WYN WILLIAMS: Obviously you'd had nothing to do with 11 past so that helped. 12 A. Nothing to do with the past, nothing to do with 13 investigations. I think there were -- Nick Read asked 14 me to chair it. I think it was felt that a member of 15 the Executive Team should sit on the panel considering 16 its importance. My understanding is a number of other 17 members of the Executive Team were conflicted because of 18 their role, and others were also chairing other panels. 19 So I was asked by Nick to chair Project Phoenix. 20 MS PRICE: Thinking back to your comments at paragraph 33 21 about there being a positive culture of constructive 22 challenge in the Post Office, the reference to the 23 verbalised view, of at least some, that this was 24 a "witch hunt", is that an example of resistance to 25 challenge within the Post Office? 54 1 A. Well, I don't recognise the phrase "witch hunt"; I've 2 never heard it being used. So I couldn't say, really. 3 Q. That document can come down now. Thank you. 4 I'd like to come, please, to whistleblowing culture 5 at the Post Office. At paragraph 67 of your statement 6 you say that at Post Office whistleblowing is encouraged 7 much more than other organisations you've worked in, and 8 you also explain at paragraph 68 that you had chaired 9 an investigation into a whistleblower's accusation, 10 there were many more investigations under way than 11 elsewhere that you have worked and, in your view, these 12 investigations are taken seriously and confidentiality 13 is respected; does that remain your view? 14 A. Yes. 15 Q. Could we have on screen, please, POL00448519. This is 16 a letter from Post Office Limited Whistleblowers, dated 17 28 May 2024 to Nigel Railton, a number of MPs, the Chair 18 of this Inquiry and lead Counsel to the Inquiry. The 19 first paragraph of the letter says this: 20 "We are writing to you as a group of highly 21 disenfranchised [Post Office Limited] employees, to seek 22 your support in addressing the ongoing intolerable 23 leadership and cover up within [Post Office Limited]. 24 We represent a significant group from all levels of 25 [Post Office Limited], who are sick and tired of being 55 1 lied to and watching certain managers being favoured and 2 protected, because they are part of the inner circle of 3 Nick Read. The culture is terrible, there has never 4 been a plan in place to address the wrongs of the past 5 (recent key indicators are showing significantly 6 declining trends in our culture and trust between senior 7 leaders and the rest of the business). Worse still, the 8 current flawed leadership is not being appropriately and 9 objectively held accountable." 10 Were you aware, when you were at the Post Office, 11 that there were Post Office employees with this strength 12 of feeling about their place of work? 13 A. No, not -- this is particularly an emotional letter, so 14 look, you know, we could see the results of various 15 engagement surveys, so, as an Executive Team, we were 16 aware that there's a lot more work to be done in terms 17 of the trust in leadership and overall morale of the 18 team, but I hadn't seen this particular letter until it 19 was given to me last week. 20 Q. Having read through the letter now and without going 21 through them one by one, were you aware of the 22 particular allegations contained within it? 23 A. I mean, it covers a lot of different points, but 24 specifically, no. No. 25 Q. That document can come down now. Thank you. 56 1 Do you believe that the Post Office's whistleblowing 2 policy has been effective in remedying past issues 3 within Post Office's culture? 4 A. It's difficult for me to answer that because the very 5 nature of whistleblowing investigations are 6 confidential. So, in terms of the nature of the 7 allegations, the findings, whether they're upheld or 8 not, and the subsequent lessons learnt, it's difficult 9 to answer that question because those aren't available 10 to me. 11 Q. You appear in your statement to interpret a significant 12 number of whistleblowing investigations to be reflective 13 of a changed culture, one that's receptive to 14 whistleblowing; is that right? 15 A. Yes, I think that's fair. 16 Q. Might a significant number of investigations also be 17 reflective of a reaction to the current culture? 18 A. Yes, it might. 19 Q. I'd like to come, please, to Post Office governance and 20 effectiveness. Could we have on screen, please, 21 paragraph 25 of Mr Brocklesby's statement. That's 22 page 8. You say: 23 "In terms of Board structure, decision making 24 responsibility lies with the Board across a wide range 25 of areas. In my opinion, the CEO does not have 57 1 sufficient delegated financial authority, which means 2 that many decisions need to be signed off by the Board 3 as a whole. Any business case or procurement activity 4 over £5 million must be signed off by the Board. 5 Although this a large figure, given the size of [Post 6 Office Limited], there is a significant number of spends 7 which meet this threshold. Procurement activity 8 typically requires two Board visits; the first to agree 9 a procurement strategy and the second to agree the 10 contract award. The Board agenda is often full of 11 procurement and business case approvals due to the lack 12 of delegated authority to the CEO or SEG, as well as 13 updates on remediation matters." 14 You go on to say at paragraph 26 that the Post 15 Office Board spends more time on operational rather than 16 strategic issues. 17 In your view, what is the impact of these features 18 you discuss, in terms of longer-term planning? 19 A. It's exactly that: that the Board doesn't spend a lot of 20 time thinking ahead, in my view, in terms of how the 21 Post Office needs to build on the future. It's always 22 looking at what's -- you know, the current operational 23 matters that are before it. So my expectation and my 24 previous experience of boards is that their role is to 25 be able to take a step back and to challenge the exec in 58 1 terms of medium and long-term strategy and whether 2 an organisation is on the right trajectory, rather than 3 constantly being drawn into the details of the operation 4 of the organisation as it is today. 5 Q. Going to page 11, please, and paragraph 35, you discuss 6 here a significant change in the SEG and Board 7 membership over the year you were at Post Office 8 Limited: 9 "... which obviously has had an impact on corporate 10 knowledge and direction ... for an organisation of this 11 scale and complexity and in view of the current 12 challenges it is dealing with (including the Inquiry), 13 it is less than optimal that [Post Office] is, and has 14 been for some period, operating with a large proportion 15 of 'interim' senior managers and leaders. It is 16 important for the stability of [Post Office Limited] 17 that permanent appointments are made through the 18 appropriate rigorous recruitment processes." 19 The high turnover point is one you return to at 20 paragraph 59, that's page 17, please. You explain that: 21 "One of the major issues with SEG has been the high 22 turnover. When [you] joined in August 2023 there were 23 ten members. Of those, only three remain in the current 24 team, with five new members. Owen Woodley retires ... 25 in August, leaving the Chief of Staff and myself as the 59 1 only remaining members of the team from August 2023 ... 2 this means there is a lack of corporate knowledge and 3 understanding of context although this does mean that 4 there is new experience available." 5 Why do you think there has been such a high turnover 6 of staff at the senior level? 7 A. There are lots of reasons why there have been -- people 8 have come and gone. Clearly some people have resigned. 9 It's a difficult place to work. It's been 10 an organisation that's been in crisis management during 11 my tenure. Clearly, with the arrival of our new interim 12 Chair, he has decided to bring in a number of new 13 members of the Executive Team as well. So I don't think 14 there's one underlying reason, but there has been a lot 15 of change. 16 Q. Is high turnover something which applies at the middle 17 management level in Post Office or is it really 18 an Executive and Board level issue? 19 A. Yes, I think it is mainly an Executive and Board level 20 issue. 21 Q. You conclude in this way at paragraph 62 over the page, 22 please: 23 "It is too early to know whether these individuals 24 [that's new individuals to the team] can work 25 effectively together to create a strong SEG team 60 1 something that has been lacking due to the high turnover 2 and constant crisis management which has been 3 a recurring theme of 2024. In my view SEG members have 4 been working at an unsustainable intensity and pressure 5 for some time." 6 Do you consider that the Post Office Board, as it 7 was when you left the Post Office last month, to be 8 effective? 9 A. That's a difficult one to answer succinctly. 10 Ultimately, I think there's lots of improvements that 11 need to be made in the way that the Post Office is 12 governed, the way that the Board operates, what they 13 focused their time on, the proportionality of different 14 topics and themes, the way that the Board engages with 15 the rest of the Post Office, postmasters and the 16 Executive Team, where there isn't much engagement from 17 the Board. 18 So I think there are lots of ways that the way the 19 Board operates needs to be improved. 20 Q. That document can come down now. Thank you. 21 In terms of your own appointment and the way your 22 contract was handled, you say in your statement that the 23 mutual intent was for you to join as a full-time 24 employee as Chief Transformation Officer and the terms 25 of your employment were negotiated on that basis; is 61 1 that right? 2 A. Correct. 3 Q. It's right, though, isn't it, that you commenced as 4 a contractor instead? 5 A. Correct. 6 Q. Why was that? 7 A. What I was told was that, despite RemCo having approved 8 my appointment, it was subsequently considered necessary 9 for the Department to also sign off on my appointment, 10 and my understanding is that approval was never 11 received. So I continued on a contract basis. 12 Q. How long did you expect that you would be working on 13 a contractor-based contract when you started? 14 A. A matter of weeks. 15 Q. But one was not approved at all in your tenure? 16 A. Correct. 17 Q. What do you think accounts for that state of affairs? 18 A. I don't know. I asked on a number of occasions as to 19 what was happening, and whether that was going to 20 ultimately be approved. But it was unclear why that 21 approval hadn't been given. 22 Q. You say at paragraph 80 of your statement that you were 23 told in July of this year, by the acting CEO, that your 24 contract was not going to be extended as he and the 25 interim Chair wanted to bring in someone with a fresh 62 1 perspective. You had been there for only a year? 2 A. Yes. 3 Q. What was your reaction to this reason for not extending 4 your contract? 5 A. I was disappointed, I was fully committed to Post 6 Office. When I was recruited by Nick Read, I absolutely 7 committed to him that it was something like a three-year 8 tenure, to make sure that I could make a difference, and 9 particularly break the back of the NBIT deployment. But 10 by then a number of new SEG members were being brought 11 in, particularly from Camelot, that were known to the 12 new interim Chair. So that had happened previously with 13 other roles, and now that was happening with the Chief 14 Transformation Officer role. 15 MS PRICE: Sir, those are all the questions that I have for 16 Mr Brocklesby. There may be some CP questions. There's 17 at least two sets of CP questions -- three sets of CP 18 questions, sir. 19 Questioned by SIR WYN WILLIAMS 20 SIR WYN WILLIAMS: All right. 21 Let me just ask: when you departed, who took over 22 your role? 23 A. A gentleman named Andy Nice, who was the former Chief 24 Transformation Officer at Camelot. 25 SIR WYN WILLIAMS: So it was someone brought in? 63 1 A. Yes. 2 SIR WYN WILLIAMS: Not at the Post Office? 3 A. On an interim basis. 4 SIR WYN WILLIAMS: Yes, he's on an interim basis as well? 5 A. Yes. 6 SIR WYN WILLIAMS: Right, fine. Thank you. Let the CPs ask 7 their questions, then. 8 MS PRICE: Thank you, sir. Starting with Ms Page. 9 Questioned by MS PAGE 10 MS PAGE: Mr Brocklesby, thank you. Can I just ask about 11 Project Phoenix again very briefly. 12 A. Yes. 13 Q. It started in January of this year. Why did it start 14 then? 15 A. I don't know, I'm afraid. 16 Q. Was it because there was a furore after Steve Bradshaw 17 gave evidence at this Inquiry and it was revealed that 18 he was still effectively working in a post he should not 19 have been? 20 A. I don't know that for sure. You know, he was clearly 21 named in a number of the cases within scope for Project 22 Phoenix so it is definitely any part of the 23 investigation. 24 Q. Do you have any light to shed on why nothing was done 25 about that between, let's say, the Hamilton rulings and 64 1 January this year? 2 A. No. 3 MS PAGE: Thank you. Those are my questions. 4 SIR WYN WILLIAMS: Next, please. 5 Questioned by MS PATRICK 6 MS PATRICK: Thank you, sir. 7 Good morning, Mr Brocklesby. My name is Angela 8 Patrick and I act for a number of subpostmasters who 9 were convicted and have since had their convictions 10 overturned. 11 I have a couple of questions about one document, and 12 if we could go to POL00448648, I'd be grateful. I want 13 to look at one issue and it's going back and picking up 14 again the question of NBIT and the Fujitsu extension. 15 We'll just wait until the document comes up. 16 It should appear, it's going to be the minutes of 17 the Board from 4 June this year. Thank you. 18 Can you see that there, Mr Brocklesby? 19 A. I do. 20 Q. If we can see your name, you were in attendance at this 21 meeting; can you see that there? 22 A. I do. 23 Q. I want to ask about a few items in the minutes. Can we 24 look at page 5 at the bottom, please, under section 3.5, 25 please. Now, this is June this year, shortly before you 65 1 left, I think, in September. We can see here there's 2 a section on the Investment Committee and the Inquiry 3 has heard a little bit about the Investment Committee 4 and its oversight of NBIT. It says here: 5 "The IC met on 16 May and focused on SPM." 6 Now, first, "SPM", is that Strategic Platform 7 Modernisation? 8 A. That's correct. It's the programme name that is 9 delivering the NBIT -- 10 Q. Thank you, that's it. So it's the overarching programme 11 which is responsible for NBIT? 12 A. Yes. 13 Q. Great. It goes on: 14 "There were uncertainties in respect of the project 15 across a number of issues including funding. Two 16 external reviews had been completed in respect of the 17 project and both concluded red ratings. The build/buy 18 point had been considered, although the build approach 19 without the necessary in-house expertise seemed flawed. 20 NRa [I think that's Nigel Railton] shared his view that 21 the conversation on buy/built was the wrong question and 22 thought that the question was build/build and then the 23 question was whether to build internally or externally. 24 There needed to be a number of conditions met for 25 a successful internal build however such as a staple 66 1 business, good governance and quick decision making. 2 With the Company not fulfilling these conditions the 3 view of NRa was that a third party should be 4 commissioned to build. NRa advised that he saw 5 3 options, firstly, SPM could carry on as was, secondly 6 a third party could be engaged to build the new system, 7 and thirdly that Horizon could be brought in house. All 8 of these options needed to be carefully considered." 9 It talks about the dashboard reporting up to IC, and 10 then the last paragraph: 11 "The Chair noted that the paper ... included in the 12 pack seemed surprisingly positive", and so on. 13 So this is June this year -- 14 A. Yes. 15 Q. -- almost a year after you've come into post and quite 16 some considerable time after of the judgments in the 17 Common Issues judgment and the Horizon Issues judgment. 18 Now, were there still conversations going on in the 19 business as to whether the replacement Horizon would be 20 bought or built, in June this year? 21 Sorry, you're nodding, Mr Brocklesby. If you're 22 saying yes or no, you have to say so for the transcript. 23 A. This was not a conversation that I was included within, 24 so this is a report from the Chair of the Investment 25 Committee, so I am reading the paper and nodding because 67 1 clearly it's a report of a conversation at the Board 2 that I wasn't included in. So, yes, there was 3 a conversation at a Board Meeting. 4 Q. I only ask you because, at this point, as I understand 5 it, you would have been responsible for oversight of 6 NBIT still? 7 A. Yes. 8 Q. Were there still conversations going on about what the 9 replacement would look like, whether it was being bought 10 from somebody else, built in-house, built by somebody 11 else or, as a third option: bringing Horizon as it stood 12 back in-house at the Post Office, as late as this year, 13 in June? 14 A. Yes. 15 Q. Thank you. 16 A. I think the logic here is somewhat confused. The point 17 about Horizon insourcing, I think, is a separate point 18 because, clearly, it doesn't get you to the same 19 outcome, which is a replacement for Horizon. The new 20 interim Chair came in with a very clear view that he 21 thought that Horizon should be insourced, and that is 22 being considered, I understand, as we speak, and there 23 may well have been a decision at the September Board 24 meeting after my departure, and I think that's 25 completely separate from how to progress with SPM. 68 1 I would say I find the debate about -- in a kind of 2 build ourselves or build with a third party, also 3 slightly odd, in as much that we aren't just building -- 4 I say "we" -- sorry, I've left, I revert to that, 5 I can't help myself -- the Post Office has two very 6 material partners in Accenture and Coforge, so they're 7 not trying to build the system completely on its own. 8 It's got two expert development partners working 9 alongside it in order to build the new NBIT application. 10 Q. We may come back to that issue about whether to build, 11 buy or bring in-house in a moment. But there, when it 12 says, "The Chair noted the paper seemed surprisingly 13 positive", were you involved in whether there was any 14 response to the Chair's question mark about whether the 15 paper was surprisingly positive? 16 A. Well, clearly, it refers to the fact that there is 17 a separate paper to be presented later in the meeting. 18 Q. Okay. 19 A. So I presume would have responded to any questions that 20 the Chair had at that time. 21 Q. Okay. Thank you. There is at least a part of the 22 meeting I would like us to look at and, unfortunately, 23 I have to find the page reference, so if you could bear 24 with me for a moment. 25 I'd like to look next at the section on transforming 69 1 technology, which starts on page 10. If we could scroll 2 down to that, I'd be very grateful. It's section 7.1. 3 I think we can see there you do join the meeting at 4 a later point -- 5 A. Yes. 6 Q. -- and you speak to a paper entitled "SPMP Update 7 Paper", and that you're going to be talking about the 8 last update to the Board and updating on progress sense. 9 You're talking about the spectrum of services available. 10 You say that there's ongoing engagement with postmasters 11 and it had been well received. 12 At that point, you said it had been remaining within 13 budget and there was progress being made on recruitment, 14 and you going on to contractors working on the 15 programme, and so on and so forth. You wanted to talk 16 about some details there. I don't want to ask about 17 that; I want to ask about the next page. So if we could 18 scroll down, and we see there "SI", who I think is Saf 19 Ismail? 20 A. Yes. 21 Q. Yes: 22 "... referenced the recent articles in Computer 23 Weekly and queried the mood in the team. CB [which 24 I think is you] outlined the 2 articles which had 25 covered the potential Fujitsu contract extension and the 70 1 IPA review. [You] advised that the articles had not 2 been well received and a number of questions had come in 3 from Fujitsu and the banks ..." 4 You say, in relation to the IPA review, you were 5 asked by SJ whether you were confident and whether it 6 would go through and answer all the points in the review 7 satisfactorily, and you answered that. 8 If we go on a little bit further, at the bottom -- 9 I apologise for this, I'm trying to find the relevant 10 section -- if you then go to the bottom, you say, the 11 next section after that, that SO spoke to a paper 12 outlining the proposal for a five-year exit plan for 13 Fujitsu. 14 Now "SO", would that be Simon Oldnall. 15 A. Yes. 16 Q. He's your direct report? 17 A. He is. 18 Q. It says: 19 "SO advised that the Board were being asked to 20 include in the strategy a stage where if NBIT was not 21 completed within the term of the extension that the 22 Company would put in place an alternative approach to 23 supporting the Horizon platform to make sure that 24 Fujitsu was still able to exit at the 5-year point. SJ 25 queried what the alternative approach would constitute. 71 1 [Simon Oldnall] advised that the Horizon platform could 2 be brought inhouse or procurement undertaken for 3 external support for the platform. SO estimated that it 4 would be 18 months to 2 years when a decision would need 5 to be taken on this point ..." 6 So just to take all of that on board, this sounds as 7 though planning is going on for Horizon still to be in 8 place, even after the prospect of an extension for five 9 years with Fujitsu; is that fair? 10 A. No. So may I explain? 11 Q. Yes, please do. 12 A. So when we approached Fujitsu for an extension, one of 13 their immediate responses was, "This has to be the last 14 time, we don't want to extend our arrangements with Post 15 Office but we understand you're reliant on us and, 16 ultimately, we will need to and we will extend". 17 We then talked about a proposal for up to five 18 years, which covered the plan to build NBIT and deploy 19 it by the end of 2028, and gave us contingency if there 20 were further delays. This was a request from Fujitsu to 21 say, "Based on the fact that this has to be the last 22 time you extend the contract, we, Fujitsu, want to 23 include in the terms of that extension a guarantee that, 24 if for whatever reason NBIT is not fully deployed by the 25 end of the five-year term, that you will instigate 72 1 an alternative strategy to make sure that you are no 2 longer reliant on us to support Horizon". 3 So it was us responding to requests from Fujitsu 4 rather than us undertaking in any way a plan to extend 5 Horizon after that time period. 6 Q. Indeed. It's being requested by Fujitsu but this is now 7 some time on. As you said, you came in in mid-2023, 8 we're talking, several years after the judgments in the 9 Common Issues judgment and the Horizon Issues judgment, 10 when some of our clients had been raising problems with 11 Horizon for near decades. 12 Now, we are now here and the prospect of a drift 13 where Horizon would stay in place, albeit brought 14 in-house under the Post Office's auspices, that's 15 a conversation that's on the table with the Board, isn't 16 it? 17 A. It's a response to a request from our supplier. 18 Q. Is it a realistic request from your supplier, noticing 19 that perhaps there has been some considerable drift in 20 this project already? 21 A. I don't believe it was realistic to assume that Horizon 22 would be operating past March 2030. 23 MS PATRICK: Okay, thank you, Mr Brocklesby. That's all the 24 questions I have for you. 25 THE WITNESS: Okay, thank you. 73 1 Questioned by MR STEIN 2 MR STEIN: Sir, could the document remain on the screen that 3 we currently have. Could we go, please, to page 12 of 4 the document, middle of the page, please. 5 If we look there and highlight "The Board RESOLVED 6 that"; do you see that entry, Mr Brocklesby? 7 A. I do. 8 Q. I think this is what you've been trying to say. First 9 of all, let's just understand, for the Chair's note, 10 that the Board resolved at this June meeting that: 11 "Subject to seeking a 3-year break provision, the 12 proposed strategy for an extension of up to 5 years of 13 the Horizon Support contract with Fujitsu from 1 April 14 2025 [written with no irony] until 31 March 2030 be and 15 is hereby APPROVED ..." 16 So that's the first part, yes? 17 A. Yes. 18 Q. So what this is essentially saying is that the Board is 19 approving the extension until 2030 of the contract with 20 Fujitsu and then, point (ii), there is reference to: 21 "The inclusion of a binding commitment to Fujitsu 22 that an alternative approach to supporting the Horizon 23 platform through commencement of a programme to 24 insource/reprocure elements [other corporate speak] be 25 activated if there is not sufficient time within the 74 1 term extension to fully migrate from Horizon to NBIT 2 ..." 3 So that's what I think you've been trying to say: 4 essentially the extension is approved for five years 5 and, within that time, frankly, fingers crossed, 6 hopefully you can sort it out in-house? 7 A. The second point is: if during the intervening period 8 between now and 31 March, it becomes apparent that 9 Horizon is required before 31 March, we will commit to 10 initiating an insource project in sufficient time so 11 that we don't have to go back to Fujitsu and ask them to 12 extend yet again past 31 March 2030. 13 Q. So the crux of this is that the Board has approved the 14 extension of the Horizon system and its use by 15 subpostmasters until 2030; do you agree? 16 A. If required. But the contract is such that it's up to 17 five years, so we can terminate earlier, when and if 18 NBIT is deployed. So it might be up to five years, but 19 if the plan sticks as it is today, then that would be 20 terminated earlier, namely at the end of 2028. 21 Q. Right, and things always go extremely well at the Post 22 Office in terms of meeting timings, requirement and 23 output; do you agree? 24 A. We have a plan -- 25 Q. Yes. 75 1 A. -- I think a well-constructed plan to get the system 2 delivered by the end of '28. 3 Q. All right. Let's have a look at something else. 4 POL00000254, page 34. We can see there, page 1, 5 "Standard Subpostmasters Contract". There may be 6 different versions of this, I'm aware they exist on our 7 document system, but this is the one that I think will 8 at least help us with what happened after the Fraser 9 judgments and, therefore, what happened in relation to 10 at least the drafting of contracts and subpostmasters in 11 that regard. Page 34, please. 12 I'm going to take us to paragraphs 20.4, 20.5 and 13 20.6. If those three could be highlighted, I'd be 14 grateful. 15 So Mr Brocklesby, these are contracts that have been 16 looked at, considered, after the Horizon High Court 17 judgments, okay? Right. Now I'm assuming that when you 18 came into post you must have read those judgments? 19 A. The judgments, not the contract, yes. 20 Q. Right, well, you read the judgments, and then one of 21 your jobs, if not the main job, was to implement, if you 22 like, the result of those judgments; is that correct? 23 A. Yes, many of those judgments had already been 24 implemented -- 25 Q. Right. 76 1 A. -- by my arrival. 2 Q. You're aware, having read those judgments, that, if you 3 like, the starting point for all of the scandal is that 4 subpostmasters were being blamed for shortfalls and told 5 to pay up, and all too often prosecuted; you're aware of 6 that background, it's a simple background? 7 A. I am aware of that. 8 Q. Okay, let's have a look then at 20.4 and see what the 9 contract was saying then about matters after the 10 judgment. So 20.4: 11 "Properly and accurately produce all relevant 12 records and/or explain all relevant transactions and/or 13 any alleged or apparent shortfalls attributed to the 14 subpostmaster ..." 15 Then 20.5: 16 "Cooperate in seeking to identify the possible or 17 likely causes of any apparent or alleged shortfalls ..." 18 In 20.6, there's a kind of cover-all, I'll read this 19 one more slowly: 20 "Seek to identify the causes of any apparent or 21 alleged shortfalls, in any event ..." 22 Okay? 23 A. Yes. 24 Q. Right. So you understand the historic background. High 25 Court judgments, shortfalls, problematic subpostmasters, 77 1 people being prosecuted, contract being amended to try 2 and make sure that shortfalls are looked at and 3 considered carefully. 4 Right. Now, you answered a question of Ms Price's 5 earlier about shortfall matters and investigation. Your 6 answer was this: you're not aware of that level of 7 detail, in other words what is going on to investigate 8 shortfalls. 9 A. I'm not aware of, yes, the investigation into individual 10 shortfalls with postmasters. 11 Q. Well, how, then, is this contractual term being 12 maintained, and I use the cover-all one, because that's 13 the simplest one to look at here: 14 "Seeking to identify the causes of any apparent or 15 alleged shortfalls, in any event ..." 16 Now, that's to say to people, subpostmasters, that, 17 "Look, we're taking this seriously. We're going to look 18 at shortfalls. If you've got a shortfall, don't worry, 19 we're going to cover it". How is that being maintained 20 in terms of a contractual requirement? 21 A. By the Business Support Team and the Network Support 22 Team -- 23 Q. That's who; how? 24 A. People in the Retail Team, people are -- that man the 25 business support phone lines that respond to 78 1 postmasters' queries, people who respond to postmasters 2 when they hit the Review and Dispute button. 3 Q. Right. So the Dispute button and the phone lines, who 4 is maintaining the monitoring of the phone line and 5 where is that reported to? 6 A. Into the Retail Team at Post Office. 7 Q. Right. Is that reported to the Board? 8 A. It reports into the SEG -- who are responsible and, 9 ultimately, of course, everything reports in to the 10 Board, yes. 11 Q. As an example, are issues that are commonly occurring in 12 relation to the helplines summarised, given maybe 13 percentage number, sent up to the Board for the Board to 14 review, so they can keep an eye on this? 15 A. It's not my part of my responsibility, was not part of 16 my responsibility. I'm aware that there's a retail 17 dashboard that's quite a detailed dashboard, with a lot 18 of data in terms of how those teams are operating, and 19 that is a dashboard that's reviewed by SEG and the Board 20 on a monthly basis. 21 Q. Is that a long way of saying, "I don't know whether it's 22 summarised and put to the Board in a way that analyses 23 the commonly occurring issues"? 24 A. It's not -- it wasn't part of my responsibilities to run 25 those teams. 79 1 Q. So you don't know. Right. 2 Now, you were referred to the letter from 3 Mr Patterson, dated 17 May '24. I'll have that on 4 screen, please, FUJ00243199. I'm grateful. Scroll 5 down, please, and stop there if you would. What it says 6 there, second paragraph: 7 "To be clear FSL [Fujitsu] will not support the Post 8 Office to act against postmasters. We will not provide 9 support for any enforcement actions, taken by the Post 10 Office against postmasters, whether civil or criminal, 11 for alleged shortfalls, fraud or false accounting." 12 Then continue down to "pursuit of Shortfalls from 13 Postmasters", please, section, at point (ii) of that 14 page. We've looked at this before, Mr Brocklesby, so 15 I'm going to cut this down to the last sentence. So 16 this is from Fujitsu, this is Mr Patterson, who, if 17 I remember correctly, European Manager of Fujitsu. This 18 is some that should know his stuff. It's saying this, 19 "Pursuit of Shortfalls from Postmasters": 20 "It should not be relying on Horizon data as the 21 basis for such shortfall enforcement." 22 Then further down, please -- I don't think I need 23 take it any further on that. 24 This appears to be Mr Patterson saying, not just 25 about criminal matters, it's about shortfalls, it's 80 1 about enforcement, it's about analysis or provide -- or 2 use of Horizon system data, and it's essentially saying, 3 this is Fujitsu, "Given the history of this matter, 4 given problems with systems, don't use our data". 5 That's Fujitsu saying that. 6 Now, when we go back in time to look at this 7 contractual requirement that I've been discussing with 8 you about shortfalls, to analyse, look into, consider 9 those shortfalls, how on earth is that being done with 10 Fujitsu being involved, if they're not prepared to play 11 ball? 12 A. I was very surprised by this letter when I was shown it 13 by Nick Read. My initial reaction was to check whether 14 anything had changed, whether any new defects had been 15 raised by either ourselves or Fujitsu, and they hadn't. 16 I didn't understand the fact that they were prepared to 17 provide detailed data in paragraph 3 here to assist with 18 postmaster redress, but weren't then suggesting that 19 exactly the same data could be relied upon for shortfall 20 enforcement. It didn't strike me as consistent. 21 I believed at the time this letter was written 22 specifically to be discovered by this Inquiry, and 23 I could see no other reason why, at this particular 24 time, considering that this version of Horizon has been 25 supported by Fujitsu for many years, they have hundreds 81 1 of technical experts supporting Horizon, they know that 2 it's used by postmasters on a daily basis to run every 3 aspect of their business, and we have an open book in 4 terms of the outstanding defects on the system, and they 5 know that none of those branch affecting defects would 6 materially impact any of the data on the system, that 7 I didn't understand why this statement had been made. 8 Q. Let me test that in two different ways. First of all, 9 in your answers to Ms Price earlier you were saying that 10 you believed that this letter related to a particular 11 criminal case. That's my summary of what you appeared 12 to be saying. So you seemed to be saying that it was 13 connected with a criminal matter. One of the reasons 14 why I've raised it with you Mr Brocklesby -- you can 15 speak in a moment, forgive me for putting it that way -- 16 is because I just wanted to make sure that you are aware 17 that letter covered more than just criminal matters: it 18 covered civil matters, it covered shortfalls. So your 19 understanding of this letter was it based upon what you 20 thought at the time, in your recollection, were criminal 21 matters only? 22 A. No, when I answered the previous question from Ms Price, 23 I was responding to a question about the first 24 paragraph. 25 Q. My second point, in terms of testing what you're saying 82 1 about this. We've gone to the 2020 version of 2 a contract that is post-Mr Justice Fraser's judgments, 3 so it is one that is clearly designed to try to say that 4 "Shortfalls are not to be tolerated, we're going to look 5 into them". 6 That's 2020. This letter is four years after that. 7 How on earth has a situation arisen whereby, from 2020 8 to 2024, it's taken all that time that Fujitsu don't 9 believe you can rely on their data from the Horizon 10 system to look at these things like shortfalls? 11 A. Well, I think that is a question for Fujitsu. 12 Q. Well, it isn't, Mr Brocklesby, because one of the things 13 that you were brought in to do -- 14 SIR WYN WILLIAMS: Mr Stein, he hasn't been there for three 15 of the four years. So I think it's a question that's 16 too wide in its current form. 17 MR STEIN: I'll cut it down. 18 You were there for about a year, Mr Brocklesby. One 19 of the issues, it relates to what's going on with the 20 system, trying to implement the changes that were put 21 forward through the judgments at the High Court. You 22 started in, I think, May 2023. Why, between May '23 23 until the time whereby you're essentially being asked to 24 leave the company, why did you not look into the 25 question of what support is Fujitsu playing in terms of 83 1 looking at this data question? 2 A. So I started in August '23. There was no equivalent 3 issue raised by Fujitsu until this letter, later in 4 2024. So there was nothing to respond to, in terms of 5 their question. 6 Q. Why didn't Post Office check to see what support Fujitsu 7 was prepared to supply? I mean, I accept entirely you 8 came in in '23, that's years later. But it seems as 9 though nobody has looked at this and said to Fujitsu 10 "Hang on, everybody, will you provide support for this 11 function?" 12 A. It was providing support for this function, it was -- 13 SIR WYN WILLIAMS: Well, that's the question I wanted to ask 14 you, Mr Brocklesby. Until this exchange of 15 correspondence, which I accept began with a request by 16 the Post Office that Fujitsu should facilitate a police 17 investigation, and then it widened out in the way that 18 Mr Stein has drawn attention to, until this exchange of 19 correspondence, had Fujitsu said anything along the 20 lines that they'd said in this correspondence, or failed 21 to provide support? 22 A. Not to my knowledge, no, sir. 23 SIR WYN WILLIAMS: Right. 24 MR STEIN: The question I've got that arises out of that is 25 this: what protocols, guidance, agreements were put in 84 1 place, to your knowledge, post-the Horizon judgment and 2 the High Court, with Fujitsu, to ensure that they 3 provided such data for shortfall consideration? So what 4 guidance, protocols, or documents or agreements were put 5 in place with Fujitsu, so that they were providing the 6 material? 7 A. I don't know in any level of detail but, for example, 8 there's an ARQ process, which -- whereby we could 9 request specific data, transactional level data from 10 Fujitsu to help with various investigations. That was 11 something that was common practice. 12 Q. Okay, Mr Brocklesby. Let's try one more time on this. 13 So 2024, revision of contract. You would have thought 14 that the Post Office would have checked with Fujitsu in 15 some form of agreement, a document, a protocol, 16 guidance, some way of judging that Fujitsu were on board 17 with this type of investigation looked at in the 18 contract. Are you aware of any such of a discussion 19 document, agreement protocol? 20 A. No. 21 Q. Fine. I'm going to take you to the YouGov document, 22 please, which is EXPG0000007, page 4, please. Grateful. 23 Can that be expanded? Yes, thank you very much. 24 If you can just go down the page, this is the 25 "Executive summary", as you can see, Mr Brocklesby. 85 1 A. Yes. 2 Q. Okay, let's look at the second paragraph: 3 "The vast majority (92%) of SPMs surveyed reported 4 experiencing some form of issue with the Horizon IT 5 system in the last 12 months. This most commonly took 6 the form of screen freezes (70%) and/or loss of 7 connection ..." 8 Moving on: 9 "Over half (57%) said that they have experienced 10 unexplained discrepancies, with lower but still 11 significant proportions mentioning unexplained 12 transactions ... missing transactions", and so on. 13 Then further down under "Discrepancies in the 14 Horizon IT System", if we look, then, at the second 15 paragraph again: 16 "Almost all (98%) of the SPMs surveyed who have 17 experienced a discrepancy reported that they were 18 shortfalls, whilst around a third (34%) had also 19 experienced surpluses." 20 Then perhaps crucially: 21 "When asked how these discrepancies were typically 22 resolved, it was most common for SPMs to report using 23 their branch's money or to have resolved it themselves 24 (74%)." 25 Now, one additional fact, the numbers of 86 1 subpostmasters surveyed, if I recall correctly, was just 2 under 1,000; it was 950 people that responded from the 3 subpostmaster group, okay? 4 A. Okay. 5 Q. Now, look, I'm no mathematician, I think anyone will 6 agree with that, but this still seems to me to be 7 a large number of people out of group of subpostmasters 8 who were experiencing still the same problems with 9 shortfalls, discrepancies, difficulties, people talking 10 about surpluses as well. So it's missing money and it's 11 too much money, and they can't resolve it, and people 12 still paying out themselves. 13 Now, I've got two real questions that arise out of 14 this: what on earth is going on with this system that, 15 in 2024, by the time of this report in September 2024, 16 that these issues are still going on, Mr Brocklesby? 17 A. I don't know how to answer that. I mean, it's something 18 that I think the Post Office would need to look into 19 further, in terms of the -- particularly the number of 20 postmasters in this survey that experienced 21 discrepancies. I mean, discrepancies can be created for 22 a whole host of reasons, and it's something that we'd 23 have to deal with -- people would have to do some more 24 analysis on, in terms of making sure that they 25 understood why these were being created. 87 1 Q. My second point about this is culture, okay? There's 2 a lot of talk about culture and we're going to get 3 further witnesses talking about culture within the Post 4 Office. 5 A. Yeah. 6 Q. What work has been done on the culture within the 7 subpostmaster branches? You've got people that have run 8 these branches for ages, under essentially a system 9 that's broken, that's poor, that has sometimes 10 tyrannised them within their branches, people are afraid 11 to come forward, even out of the group of people working 12 in the branches, and that culture is no doubt repelling 13 people, when they're getting discrepancies to still pay 14 up, not use the button that says there's a problem, not 15 use the helpline to say to them there's a problem. 16 People are still paying up for shortfalls. 17 Do you agree that there's a culture problem that has 18 yet to be addressed with the people running the 19 branches? Not their fault, it's what's happened to them 20 that's causing it; do you agree with that, 21 Mr Brocklesby? 22 A. I don't recognise a culture problem that remains, no. 23 Q. What, you don't recognise a culture problem with people 24 within the branches of the Post Office still paying up 25 for shortfalls out of their own pocket or branch money? 88 1 A. That may be valid. 2 Q. Project Phoenix, Mr Brocklesby, just so that you can 3 help a little bit further with that. We have some 4 information because some of our clients are affected by 5 this; they've essentially been at the centre of 6 investigations. Is it Project Phoenix, the project 7 that's employed ex-police officers to look into and 8 conduct investigations? 9 A. Yes, I think -- 10 Q. Have they completed something like 18 internal reviews 11 or is it more? 12 A. In terms of the cases -- 13 Q. Individual cases. 14 A. -- I think it's more. 15 Q. It's more. Have they been provided to the Inquiry? 16 A. I don't know. 17 Q. Have they been provided to the individuals who were the 18 subject of those reviews? 19 A. I don't know for sure. Certainly postmasters were -- 20 the postmasters affected were offered an interview, so 21 that they could provide more colour and clarity around 22 their original evidence to the Inquiry. 23 Q. Are the people, to your knowledge, who are the subject 24 of these reviews going to be provided with a copy of the 25 review about their issue? 89 1 A. I don't know. 2 Q. Do you not think that's a good idea, Mr Brocklesby? 3 A. Yes, I do think it's a good idea. 4 Q. You were engaged with some of the meetings with our 5 clients. These are restorative justice meetings; 6 correct? 7 A. Yes. 8 Q. You took part in the meetings, I think, in July this 9 year; is that correct? 10 A. Yes. 11 Q. I may get the numbers wrong: five, six, seven meetings, 12 something like that? 13 A. Yes, it was over two days. It may be a little more than 14 that but something like that, yes. 15 Q. These meetings, you're aware, I think, Mr Brocklesby are 16 difficult for the people that come to the restorative 17 justice meetings? 18 A. Very difficult, yes. 19 Q. You'll understand when I say that people actually have 20 to summon up the courage to actually attend at all? 21 A. I really did -- I didn't understand that before but, as 22 a consequence of going, I understand that many people 23 had suffered so much that they find it difficult to 24 travel and, in some cases, have found it very difficult 25 to talk about what they've been through and they were 90 1 very brave in my opinion in coming to those meetings. 2 Q. You'll understand that sometimes some people frankly 3 can't come to the meetings at all, don't want to take up 4 the offer -- 5 A. Yeah, I understand that. 6 Q. -- or the other way round, too angry -- 7 A. Yes. 8 Q. -- not wanting to engage; you understand that? 9 A. I do understand that. 10 Q. Mr Brocklesby, I don't know whether the right word is 11 "pleased" but you may be interested to learn that 12 people's reports about those meetings that included you 13 were very positive, that you listened, appeared to 14 listen, you appeared to gain information and you 15 appeared to be affected by the meetings and what people 16 said; is that a fair summary of how it came across to 17 you? 18 A. It is a fair summary. I found them enlightening but 19 very, very difficult. 20 Q. Do you understand also that, as we know from your 21 statement and the evidence you've given with Ms Price 22 that, therefore, when you leave the Post Office, you 23 take with you that memory, your personal memory, of 24 those meetings, the lessons you've learnt, and that that 25 part of your, if you like, corporate involvement on 91 1 behalf of the Post Office largely goes with you when you 2 leave the Post Office? 3 A. Yes. 4 Q. Do you understand that goes? Others that have taken 5 part in those meetings, I think Mr Read, who sits behind 6 me today, has also been engaged in those meetings and 7 also, we believe, has been affected by them, and he is 8 also leaving the Post Office. Did you see that what is 9 happening is that this corporate churn, these 10 individuals that are, for you, just what, about a year 11 or so at the Post Office, other individuals, longer term 12 like Mr Read at the Post Office, engaging in these 13 meetings -- I don't know whether our clients are going 14 to say it was a waste of time but it does feel a deep -- 15 there seems to be a real shame that this understanding, 16 this knowledge, this emotional memory of what has 17 happened with subpostmasters through these discussions 18 is going to be lost from those people like yourself that 19 are leaving; do you agree? 20 A. Yes, I hope the new members of the Executive Team engage 21 in the whole process, and I certainly tried to share my 22 experiences when I returned to make sure people 23 understood, that hadn't done those sessions, just how 24 those postmasters and, I think, for me most importantly, 25 their families, had been so impacted and in ways that 92 1 I hadn't previously understood, and the fact that that 2 impact was still being felt today, in some cases decades 3 after the events that actually impacted them and their 4 families. 5 MR STEIN: One moment, Mr Brocklesby. 6 Thank you, Mr Brocklesby. 7 Further questioned by SIR WYN WILLIAMS 8 SIR WYN WILLIAMS: Mr Brocklesby, I'm sorry to go back over 9 one or two things that you've been asked about but 10 I want to get as clearly in my mind as possible where 11 the Post Office had reached in terms of the new system, 12 as I'll call it, at the date you left. All right? 13 A. Yes. 14 SIR WYN WILLIAMS: Because we've looked at lots of minutes, 15 and all the rest of it, but I want your understanding, 16 if I may, of where we had got to or where the Post 17 Office, rather, had got to. 18 A. Yes. So -- 19 SIR WYN WILLIAMS: First of all, can I work backwards? 20 A. Yes. 21 SIR WYN WILLIAMS: As of the date you left, were there, so 22 far as you were aware, any concluded contracts with 23 Fujitsu which related to any kind of extensions? 24 A. No, there were not. 25 SIR WYN WILLIAMS: Right. So when we're looking at minutes 93 1 and resolutions, that's any one side of the story. So 2 far as you know, by September 2024, there were no 3 concluded agreements? 4 A. Yes. That's correct. 5 SIR WYN WILLIAMS: Right. That's clear in my mind. 6 Second thing I want to be clear in my mind is your 7 view of what will occur if things go to plan. 8 I appreciate things may not go to plan but I'd like you 9 to tell me what you think will happen if things go to 10 plan. 11 A. Yes. Let me try and summarise. If things go to plan, 12 between now and June 2026, this new system will be 13 built. It's being built incrementally starting with 14 a certain number of the transactions that postmasters 15 use and, building on that, more and more and more 16 transactions. In parallel with that, the system will be 17 piloted in up to 50 branches, so that we get postmaster 18 feedback and experience of the new system. 19 If that all goes to plan, then from June 2026, then 20 the system will actually be starting to be deployed into 21 branches. That means starting to turn off Horizon in 22 that branch and move to that branch fully relying on 23 NBIT by postmasters to serve its customers. 24 That process of training postmasters in the new 25 system, cutting over from the old to the new, will take 94 1 the period of time between the middle of 2026 and the 2 end of 2028. 3 Through that period, the Post Office will then start 4 to be able to turn off some of the services provided by 5 Fujitsu, until the end of 2028 when it will be able to 6 turn off the final of those services and cease to rely 7 on Fujitsu to support Horizon because every branch will 8 then be using the new system to serve its customers. 9 SIR WYN WILLIAMS: My last question is: so far as you know, 10 as of September 2024, was the necessary finance for 11 those things to happen approved? 12 A. No, it was not. Because of this incremental nature to 13 funding -- 14 SIR WYN WILLIAMS: Can I just ask you, and you tell me if 15 this is too simplistic, but which part, if any, of that 16 plan did have approved finance? 17 A. It was being approved in slices, in terms of timing. So 18 all of those activities, ie activities on Horizon and 19 activities for the new system, have been approved up to 20 the early months of next calendar year. So something 21 like January and February 2025. So new funding to move 22 forward past those dates will be required in short order 23 to make sure all of those activities can continue. 24 SIR WYN WILLIAMS: Would I be correct in thinking that, if 25 finance is approved, in effect, in tranches, as it is 95 1 going along, we are talking about approving finance for 2 a period of work which covers months only, not years 3 into the future? 4 A. Yes, that is correct. The funding discussions have 5 clearly been complicated by a general election and 6 a spending review from the new government. So the 7 expectation is that, at best, the next tranche of 8 funding would be for another year, to take it, I think, 9 through to March 2026. So again, that would just be 10 another tranche and other tranches would be subsequently 11 needed. 12 SIR WYN WILLIAMS: Again, if I am being too simplistic, 13 please tell me, but, ultimately, this is not the Post 14 Office funding things from its own generated funds; this 15 is all roads lead to the Treasury, yes? 16 A. That's correct. There are some projects that -- the 17 project is able to fund itself but, certainly, there are 18 a bundle of transformation projects, including the SPM 19 programme, which need to be funded outside of Post 20 Office's finances. 21 SIR WYN WILLIAMS: One last question: I have heard from 22 other witnesses that there is, as we speak, a strategy 23 review being undertaken. 24 A. That's correct. 25 SIR WYN WILLIAMS: Does that have any impact or potential 96 1 impact on the progress or otherwise of the plan that 2 you've explained to me in summary? 3 A. It absolutely does have potential impact in terms of the 4 size of the branch network -- products that will be 5 continued to be sold or discontinued would all impact 6 the scope and timelines of the project. So that does 7 deliver a certain amount of uncertainty to the 8 programme. 9 SIR WYN WILLIAMS: Well, on that note -- I won't say happy 10 or unhappy -- thank you very much for your evidence, 11 Mr Brocklesby. I am grateful to you for your witness 12 statement and for your oral evidence. 13 THE WITNESS: Thank you. 14 SIR WYN WILLIAMS: Right, Ms Price. We have a day off 15 tomorrow, do we? When I say a day off, we are not 16 having a hearing tomorrow, I think is a more accurate 17 way of putting it, and we resume again on Friday, yes? 18 MS PRICE: That is correct, sir. 19 SIR WYN WILLIAMS: Thank you very much. 20 MS PRICE: Thank you. 21 (12.59 pm) 22 (The hearing adjourned until 10.00 am 23 on Friday, 4 October 2024) 24 25 97 I N D E X CHRISTOPHER WILLIAM BROCKLESBY (affirmed) ........1 Questioned by MS PRICE ...........................1 Questioned by SIR WYN WILLIAMS ..................63 Questioned by MS PAGE ...........................64 Questioned by MS PATRICK ........................65 Questioned by MR STEIN ..........................74 Further questioned by SIR WYN WILLIAMS ..........93 98