Post Office Horizon Inquiry LIVE: Angela van den Bogerd gives evidence

eeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeee e e e e e e e e e e e e e e e e e e e e e e e e e e e e e e e e e e e e e e e e e e e e e e e e e e good morning sir, can you see and hear us? I can thank you very much, thank you. Can I call Miss Vandon Bogard, please, yes, of course? proof that I will give that the proof that I will give will be the truth will be the truth the whole truth the whole truth and nothing but the truth and nothing but the truth good morning Mrs.

Bandon Bogard my name is Jason Beer and I ask questions on behalf of the investigation, can you tell us your full name please, Angela Margaret Vanden Bogard? He has provided two detailed witness statements for the

inquiry

, so thank you very much and thank you for coming to give

evidence

today before we get into the details of those two. witness statements, I think there is something you wanted to say, it's true, thank you if I may, say I'm sorry, I know it doesn't change what happened, but I want to say to everyone affected by wrongful convictions and wrongful terminations of contracts that Really I am so sorry for the devastation caused to you, your family and your friends.

I hope my

evidence

helps this investigation get the answers you and so many others deserve. Thank you Mr. Beer. Thank you. Can we see the statements of the two witnesses, please? the first one is 114 pages long and dated March 20, 2014 and the UR, if we can show it, please is Win 9100. I think there are seven corrections you want to make to that statement. Can we start with the first one please, what is it? Page 21, paragraph 36 I think there is an addition you would like to make at the end of paragraph 36 to insert the following words: further disclosure survey 014 2481 and survey 1 7 8171 shows that I initiated the provision and analysis of Horizon records with regarding The Unexplained Loss at the Branch, so I'll read it without the um two URS.

Additional disclosure shows that I initiated provision and Analysis of Horizon records regarding The Unexplained Loss at the Branch. That's right, that's right, thank you. Second. Amendment uh page 31, paragraph 62 on line 8 um, which says: this was the first time I finished an interview, sorry, I attended an interview with a sub

post

master. I think you want to add the words like this after the assisted words so that it says this was the first time I attended this type of interview that's correct that's right thank you uh page 38 please uh paragraph 77 line seven the date the first date I think you would like to modify March 10, 2012 to May 10, 2012 is correct, yes, page 65 please, line one.

I think you would like to remove the words um, since the terms of reference have not been disclosed. That's right. I've seen them since I prepared this to be read. From memory, the purpose of Project Sparrow was to monitor the correct page 104, please, paragraph 223b at the bottom of the page. I think you might like to add the memory words to the beginning of the paragraph. So that my participation can be read by heart. correct and then at the end of the paragraph add the following words, however, more disclosed documents show that I was involved in discussions about overlaps between witness statements, that is correct, thank you, page 109, please, in paragraph 22 9 at the end of the paragraph, I think I would I would like to add the words: further disclosure shows me expressing my concerns to Andrew Parsons of wble bond Dickinson right, so further disclosure shows me expressing my concerns to Andrew Parsons of wble bond Dickinson.

Can you turn to the final page of the witness statement? Page 114. is that his signature, uh, yes, and with those corrections taken into account, the content of that testimonial statement is true to the best of his knowledge, thank you. Can we move on to the second witness statement, which is seven pages long? 9200 I think there is a correction you would like to make to what is on page six, paragraph 16 and I think you would like to remove the words that start three lines from the bottom, while I cannot correct until the end of the paragraph. right, so that whole page from when I can't and then over the page to the words the scheme corrects and instead insert the words helpline call WS no audio was recorded at the time the call logs were those used for scheme investigations. correct, thank you, sorry Mr Beer, there are two sentences that end with outline, there is the first line and the third line, where do I stop deleting?

That's all? um, is it all the way? or the first scheme, to the end, sir. and could you tell me again what the correction includes through additional words? Yes, the calls to the helpline were not audio recorded at the time, it was the call logs that were used for investigations into the scheme. Thank you very much sir. It's that his signature on page seven is yes and the content of the witness statement is true to the best of his knowledge and belief, taking into account that correction, they are yes, thank you, thank you, that can go down.

Can I start please with your career at the

post

office

uh you had an extensive career at the post

office

spanning some 35 years that's right that's right you first joined the post office in 1985 , straight from school, that's right, yes, you started as a post office counter assistant, so you worked on the counters and You were a person who rose through the organization and eventually held numerous management roles. That's right, that's right, can I describe your career path as I have understood it? In short, you were a counter assistant between 1987, 1985 and 1987, correct. you were branch manager between 1987 and 1996, correct, you were retail network director between 1996 and 2001, correct, you were area head of the rural agency in Wales between 2001 and 2005, correct, you were general manager of the community branch network . between 2005 and 2006 correct you were the national network development manager between 2006 and 2009 yes you were the network change operations manager between 2009 and 10 correct you were head of Network Services between 2010 and 2012 yes you were head of Partnerships between 2012 and 2013 yes you were program director for the branch support program between 2015 13 and 15 correct you were director of Support Services between 2015 and 16 you were director of people and changed directors between 2017 and 18 correct you were director of Services of people in 2018 yes and you were uh the business Improvement Director between 2018 and 2020, that's correct, given the length and breadth of your career, do you accept that you had extensive contact and understanding of the position of sub postmasters?

I did it, yes, do you agree that you

live

d through the development and implementation? from the

horizon

yes, I accept that you

live

d during the launch of the IMPACT program, sorry, the IMPACT program, don't you remember the IMPACT 2005 program? I'm not M it was the IMPACT program, do you accept that you lived and worked during the move to Horizon online in 2010 yes, I did the production of the Isme report in 2010 yes, uh, the production of the deta report and the deoe reports and I saw that yes , all of the prosecutions of the subpostmasters based on the evidence produced by Horizon happened when you were Yes, I was not involved in that, but yes, they happened during my time.

You were intimately involved in the second hearing in an initial investigation. Yes and with the mediation scheme. Yes, and he was extensively involved in the group's litigation. Yes, do you accept that your management. The roles allowed and in fact required you to raise the issues facing subpostmasters to senior management and then laterally to the board of directors um when I became aware of them yes um in terms of the board of directors, whether directly by myself, probably not, but through my reporting line and who their reporting line was, it depends on what time, um, so my reporting line in terms of manager roles tended to be uh Sue Huggins um Kevin Gilland uh Al Cameron uh and then my last role was reporting to um Joe McLoud so if we move forward when you were Partnerships in 2012 to 13 who was your reporting line I think it was Kevin Gilland uh program director um for the Support Program branch 13 to 15 I think it was Kevin again director of Support Services 15 to 16 sorry, that was Al Cameron uh people in the director of changes 17 to 18, so I had to uh do an online report um Al Cameron and um Martin Kirk , who was the HR Group director at the time uh people Services director in 2018 Al Cameron and business improvement director 18 to 20 J McLoud, then you wouldn't have had direct access to the board, that's what you're saying. , but through each of those reports, indirect access, so what used to happen is that if you took something to the board, you would normally have a sponsor. who was CEO and that would have been my online report um but sometimes they would call me just to give updates on the branch support program for example they might call me to come and give an update on the document um but usually your exact The director as sponsor would introduce you at that session and you would take over and update through the newspaper how many times you attended the meeting. um, oh, throughout my career, no, I didn't regularly attend the meeting, so we had the meeting and then underneath we had the executive team, so I probably would have spent more time updating the executive team and occasionally I would go to the meeting for whatever he was doing at the time, so there were other things that he would have updated the meeting on because he was involved in other things besides what we have discussed as well how many times do you think you attended the meeting? um um, I would say between 10 and 20 over my career, I probably can't be exact, you left the post office in May 2020, that's right, that's correct and you describe how you left the post office in your witness statement.

If we can upload that, the first one will appear on the screen, okay, page 110, please, at the bottom of the page, please Q. paragraph 233, you say that with the agreement reached in the group litigation in December 2019, my role came to an end as a result. I was fired, that's right, that's right. Can we please look at pven 5280 and on the page please this? is a copy of text messages exchanged between you and Paul Avenel in May 2020 and can you see that the one above is Miss Venel asking you how she is and what lockdown is like for you?

Yes, yes, and then your response is at the bottom of the page hello Paul, good to hear from you, we are all fine, thank you, I hope you are locked up too, I have been working 24/7 week, in Covid-19 crisis management for me in recent weeks, however, I leave the post. office on Monday I'm finalizing the details of my agreement and it's not common knowledge at work yet, but the time is right for me to leave. The past year has reinforced that for me, I don't know what I will do in the future, but I am looking forward to new pastors.

I'm glad some things I said were helpful. For you, take care of yourself. Etc. Yeah, you say, um, it wasn't common knowledge at work that you were leaving, but it's the right time for you to leave. The past year has reinforced that for you it seems that it was what happened the year before that was relevant to your decision to leave. Is that the right? It is correct at that time, the post office had lost its mind on common problems, the mail. The post office had lost the lawsuit over Horizon issues. The post office had failed to appeal to the appeals court and the post office had reached a settlement of more than 50 million with the plaintiffs in the group litigation. court judge were those relevant to his reasons for leaving um it wasn't really what came after that so I think um just to set the context so the only um when I moved to the branch uh Improvement, sorry , business, improvement role that was The first time I had been working exclusively in that role for my entire career, um, by including research to the second second S in the startup outline, that was in addition to my day job, so It was an additional responsibility so when I moved into the business improvement role which was supporting Glo full time um so technically when it ended my role was redundant but I didn't leave it right away because that was in December and I I left in May, so after um Then I started to get to the agreement.

I was asked to review the Horizon deficit scheme, what it would look like. And I spent some time working with the lawyers. I would have been hsf at the time and I think for me I got a little bit. disappointed as to what we had agreed to and so my view is that we should now move forward and deliver on what we said we would do, which is the Rison deficit plan um, as quickly as we should and it just wasn't happening and Why wasn't it like that? It happened because there was um, there were a lot of discussions about what that should look like, how long it should take, um, I was very disappointed, I mean, my comment to the company at the time was that Horizon, I'm sorry, thedocument can Low and can you move forward a little bit and make sure those two microphones are angled towards your mouth?

Okay, that's better, a little better if you can keep your voice up. I'll try. Sorry, I tend to lower my voice. so let me know and I'll bring it up so you said what you said and then I missed who you said it to so it was a general conversation uh within the business I said you know success would be measured. because of how quickly we paid compensation, the amount of compensation we paid and how little we spent on attorney costs to do that and I was worried that all of that would be reversed, so we were spending quite a bit of money on attorney costs and No.

We were progressing applications through that scheme as quickly as we should, but when I left in May, no payments were made and we didn't progress any further, so I became very disappointed with um, I guess the company's intention to sort out what we agreed what we would do and who was driving the company's intention to not do the three things that you've identified I'm, not really sure, um, because the lawyers were so involved, um at the time, um, it just didn't seem to get traction, I thought we should let you know, so my point of view was, you know, we were past the you know. very difficult trials, we had agreed to the agreement and therefore we accepted that position and we must move forward and do what we must do as quickly as we should so that it was not the loss of the trials and the criticism of the judge that prompted him to leave was disappointment with the post office honoring its commitments to me personally.

Yeah, I mean, I had had a conversation with Paula before I went into the trials that I was thinking about leaving the business and that was because at that point I felt like I was being pigeonholed into litigation and I wanted to explore other things from a professional perspective, so it wasn't something I hadn't discussed before, but at that point Paula had asked me to stay due to my extensive knowledge of the business and the fact that she knew I was close to the initial research with the second site and the plan, so I agreed to stay, but yeah, but it was just, it was a personal thing.

To me, as you say, we weren't following through on what we said we would do as quickly as I thought we should, did the Revelations made by The Horizon trial have no impact on you in terms of your career and your decision to leave? ? the fact that for the first time a person in the Authority, a high court judge, had discovered the existence of, say, 30 errors and defects that had or had the potential to cause deficiencies, a fact that the post office had been denying for decades has any impact On you, I think that was obviously the final position, but I think as we went through the Glo um it was obvious that things were known in terms of what I was seeing there.

They were things that I hadn't been aware of before, so to me it was like we were on that journey anyway, um, the extent of the trials, I think it was a surprise, um, but after having gone through all the process and I was you. I know yes, I attended both tests every day, but you know, um, so I could see them coming together as they went on, so it wasn't a full Reveal, um, but and and that wasn't really, that It wasn't a reason to From my perspective, leaving the business wasn't my reason, it was the fact that you know we just weren't delivering on what we said we were going to deliver on and I felt that quite strongly even though you had been directly involved in the second.

The initial investigation of the site and in the mediation process neither of which had uncovered the errors and defects that the judge found to exist and which had no impact on you at all. Well, I wish we had figured it out, but the evidence from our investigations the evidence just wasn't there to support it, but what I didn't know and my team didn't know at the time was that you know the amount of, so the records of known bugs for example, what we didn't know about the Kells at the time, so those things came to light later, as we were in the Glo process.

I think that's one of the five main things he says in his witness statement. I'm going to summarize your witness statement, if I may, first of all, I think you don't make concessions or admit that you did something wrong, right, well, I didn't know and I did something wrong and I would never do anything wrong, don't worry. excuse me I smell it because of your role. In any of the events examined by the investigation, I think you know and I have reflected quite a bit on this, you know and the disclosure that I have seen through this process, there are things that documents that I have seen that I don't remember some of them from that era, but knowing clearly what I know now, I would give more weight to some of those documents than at the time so that they had more meaning and things like I might have missed at the time, so I really regret it and I wish I could have seen it in back then, but even knowing what you know now in your witness statement, you don't apologize for anything you did wrong, right? um, I apologize for not getting to the answer faster, but with the evidence I had and the parameters of my role at the time, I did the best I could and the best I could, what you're saying is that you blame Fujitsu for not do it. being transparent with you and the post office and yes, that's the third thing you say, from my perspective you put the blame on Fujitsu because you know that we had established the mediation plan, um, we had They communicated with Fujitsu in terms of power get the information from them so we could do the investigations.

They appointed a project manager who we funded to be able to access the information we needed. I knew what we were doing but we didn't see any Kels now. I didn't know Kels existed and no one we were working with in the business knew that at the time, what I saw subsequently through outreach and what some What came to light as we were going through the GL process is that there were people within from the organization within the post office who were aware of I guess there's nothing new but I'm just talking about service management um kind of the department where they will deal with fitsu at that level on a daily basis and work on that now which was not available and I certainly wasn't aware of that when we were going through the scheme, that's the fourth thing you say.

The first information about Kels' known error records was in the course of the group litigation, yes, but when in the course of the group litigation, um, I'm not quite sure, um, but it wasn't the Kels detail. more Kels um as well as um as well as us Andrew Andrew Parsons in particular I was preparing the case and bringing documents to um I think it was the plsg so that's probably the first time um and we started to get some inquiries from the legal team. He comes in with me and then with my team so I can go and find information about it, but that was the first time, but I can't really put a date on it.

Finally, you say that you were not aware of any material error. in the Horizon system until the second site investigation was reported in July 2013, so at the time we were sending information to the second site for the construction of the interim report, we then revealed two errors and that was a surprise to me. aware of that up to that point can I um before I get into the details just look at some of the language that you use um um go back to your witness statement in paragraph um 29 on page 14 please will appear on the screen the The top paragraph, which is paragraph 29, and the word before memory on the previous page is from uh, you say from memory.

The second site was preparing its report and the legal team said they had been informed of a couple of anomalies that they needed. To disclose, this is the first time I've heard of any errors, so it was a surprise, which is what you just told us, yeah, and then you look down at paragraph 30 of the page, about three or four lines down. from the bottom, if we scroll a little further. In fact, five lines, as mentioned in the previous paragraph, it was only when the Post Office revealed to the second site that there were two anomalies within Horizon in 2013 that there was any suggestion that the system was not foolproof, but even then it was provided a rational explanation.

Experts, you refer in this statement in several places, as we have seen here, to anomalies. MH, did you choose that word because you wanted to characterize bugs, bugs, and flaws in Horizon as something strange, peculiar, or weird, I mean, the definition of the word anomaly isn't, it was just that was the word used at the time, so when I think it was Simon Baker that was involved um and it was brought to my attention and I say the legal team, I think it was Andy Parsons and Rod Williams that were the conversation was just the word that was used at the time, do you remember a um, a dictate that the word anomalies should be used?

Sorry I missed that question, yes, do you remember a dictum, an instruction, a suggestion that the word anomaly should be used? there are no additional errors and defects, errors and defects, we cannot look, please, in survey 38985, we can see, this is an email from Paul de venel to you around this time in July 2013, we can see that it is on the mailing list there, in which he says that my husband, a computer engineer, sent the following answer to the question what is a non-emotive word for bugs? errors sorry computer errors failures defects that occur as a matter of course answer exception or anomaly can also say conditional exception or anomaly that only manifests M in unforeseen circumstances, remember this?

I hadn't remembered, but I had seen this. I think it was mentioned yesterday or during this phase, so I remembered it at that time. Did you act accordingly? Instead of referring to things as bugs, flaws, defects, you should use the words anomaly or exceptions, so I don't think I've ever used the word exceptions or anomalies, so Simon Baker put together the information to provide to the second site and directed it to anomalies and that is why I just adopted the word anomaly, but in my statement I have referred to errors, in other places where we asked a question about areas of errors and defects, so I think and I am sure that there is a technical categorization for each of the errors and defects of the bags.

I don't know what that is. But if you read this now, can you see that it is an attempt through the use of language to control a narrative that Mr. Blake might call It's Orwellian, yes, it's that what it was like to work in the post office at that time, that language was controlled to lead the narrative which we certainly had throughout my time at the post office and at Royal Mail before that, so we had always agreed messages, so you know. in terms of consistency of messages and words we would use. I didn't think much about this at the time.

You know, the important thing for me at the time was that there were two errors, mistakes or flaws, whatever we want. determine them which, um, I wasn't aware of until that point, they were explaining to me, you know, this, you know, every system has these things, it's how you handle it, it's important and we go on from there, but it didn't strike me as something really unusual in that time, what didn't seem unusual to you is that we were a preferred use of language, yeah, so the agreed language that we wanted to use there and if it comes from Paula's note it was anomaly um and that's what Simon had put in so when shared that information um they were in the head anomaly um look, looking at it now, can you see what maybe lies behind this?

Yeah, what do you think is behind this? As you said, it's about controlling the narrative it's about using a consistent narrative. I don't think it really worked here because that's a different topic, yeah, because you know, by default I've failed straight up annoying, but I did agree that it was an attempt to control the narrative in terms of what we were saying and um, what do you think was the intended effect of using exception or anomaly language instead of um error, failure, or defect? Well, I think from Paula's note she says it's not emotional, um, that's what I think she said um there, but a non-emotional word um I didn't think much about it at the time I mean, do you think it's is it about emotion?

Well, I don't think it's about emotion, it's trying to suggest something materially different. an exception or anomaly carries the implication that it is strange that it is strange that it is peculiar uh yes where there is a bug what suggests that or a defect in your system what does that entail I think for me it implies that It could be exceptional to the extent that it does not We had seen a lot of them, but I think the word error is a little more routine, so you know, that's what we expect from that situation. I say no.

I didn't think much about it at the time, it was an anomaly the word um that Simon had put in the information he shared and that is why I included it in my witness statement because when I was referring to the documents, but as Let's say I instinctively omitted the error. Can I move on to a different aspect of information management than the Professional privilege?Legal, but to your knowledge, the Post Office from 2011 onwards, at least 2011 onwards, sought to use claims of Legal Professional privilege as a tool to conceal communications in privacy. I didn't think about it at the time.

Does that mean that looking back you can see how he tried to do it now? Again, from the information that I've seen as part of this process, so, um, I think. there was a tendency to do that if you sought to regulate your conduct and conduct your Communications in a way that maximized the possibility of hiding your Communications in privacy so that they would not have to be disclosed again. I wasn't aware of that, can we look at survey 0017 6467? Can we please look to start on page two? This is an October 20, 2011 email to you, among others, from Emily Springford and if we look at page three, scroll down. thank you, we can see that she was a top lawyer in dispute resolution.

I think in the male group Ro. Yes, do you remember Emily Springford? No, I had never met her. Go back to page two, please. It is about disclosure and collection of evidence in context. of the jfsa complaints and addressed the aggregate three topics um document preservation document creation and the information that is needed to respond to complaint letters and I think you have seen this yes, thank you, we have seen this before and recently, so I'm not going to read it. Can we go to something new that is your communication on page one? Can we see you send this to a collection of people?

Mr. Breeden, Miss Norbury, m. Richardson, Mr. Wales, Mr. Lawrence, Miss Buchanan, etc. Yeah, that was my um. leading the team of my direct reports so you were sending him to your team yeah he was and what he did generally speaking the people who were your direct reports do it so there was a mix um John and Lynn um they had contract they managed the contract advisor team um the rest then were um so this is just to give a little bit of context so this um when I took over I took on additional responsibilities uh I think it was December towards the end of December 2010 this was the new team that came together, he was bringing together different areas of responsibility at the time, so Lynn and John were the contract management team, the rest, had been my existing team, who managed the network of post office supply, opening, closing, and also.

I think at this point, I think I brought the training and audit function into this as well, okay, and they would have had people working under them and people working under them, would you expect them to distribute it to the people who work for them? Yes, so it would cascade through the business that way, yes, yes, and if we see that you forward Ms. Springford's email and on the second line you say that litigation is a strong possibility, our team legal has issued any guidance, any advice. guidance and directives in the email below once you have read the email, I need you to act on the relevant sections, but I want everyone on our team to be aware of the need to preserve all documents that may be relevant and potentially relevant for these claims. and you set them And and then two Mark communications in relation to these cases and, as detailed below, legally privileged and confidential, do you think that message really reflects Ms.

Springford's advice? Yes, I do. I marked all communications in relation to those cases legally privileged and confidential, yes, but that was not Miss Springford's advice, so I thought I was simply passing on Miss Springford's advice because, as I said, this was quite a team. new one that joined. Lynn and John in particular would have been aware of this, um, this guy. of requirements where the rest of the team wouldn't have been, so I was just the one who just relayed Emily Springford's instructions and requirements. What she had said, we can see on page three in the second paragraph of the top third line as Litigation is now a clear possibility: a document will be Ed privileged if its primary purpose is to provide or receive legal advice about litigation or to provide evidence for litigation use.

This also applies to communications with third parties and then the first point if the dominant purpose of the communication is not to obtain legal advice. I try to structure the document in such a way that it can be said that its dominant purpose is the collection of evidence for use in litigation now without addressing for the moment the question of whether or not. What Miss Springford advised was correct or appropriate, she was saying that only where the dominant purpose of the document was the gathering of evidence, could a document be said to enjoy a privilege that qualified its advice in relation to litigation, right? is that so?

Yes, what you advise. page one, scroll down Mark Communications in relation to these cases is a list of legally privileged and confidential cases on which the party has dropped only if the dominant purpose of the communication can be said to be obtaining or receiving legal advice. That was just a summary of CU. I asked them to familiarize themselves with Emily's note. I asked them to read it and it was just me who was actually drawing her attention to this is important. I need you to know what Emily is asking us to do. asking them to comply with that, there was nothing but me, just to summarize, let's look at it this way, at least you understood that all communications in relation to those cases are now legally privileged and confidential, well, that's not what I've said.

I have said that the communication with Mark did not tell it all, but this was a new situation for me. I hadn't been involved in outreach before and several members of my team wouldn't have been involved in outreach before, so this was me, just passing through. about Emily's requirements and requests, you're not conveying it, you're conveying it and then saying that you want everyone on the team to be aware of the need to do these three things and the second. of those things is materially different from what she advised, isn't it? It was not my intention.

This was just... my intention was just to bring it to the minds of the four people on this newly formed team so that we were aware of what we had to do and the other, the third point was to make sure that they treated all of this as a priority. because I think the moment it developed for me is that the legal team sometimes struggles. to obtain the information they needed from the business. Now you're talking about something different, which is about the priority of communications. I'm talking about the second point, so if we focus on the second point, at least you understood. that all communications had to be treated as legally privileged and confidential, right? to those cases as legally privileged and confidential when that is not the advice that was received, I don't remember that far back, but I say my intention was just to convey what Emily had asked for in terms of the summary that she had asked them for.

I read what she had said. I don't remember any more arguments after this. And yeah, I can't remember anything else after that in terms of what we did, but if there were any questions about what they were doing, they would have raised them. at that time and I don't remember any thanks coming. Can I move on to the substance, please, and first of all to the issue of remote access? Well, can we turn to your witness statement on page 10, please, in paragraph 19? I just want to look at what you say in your witness statement about remote access and then go look at some of the underlying documents.

It says one document is an email from John Breeden to me on December 5, 2010. I can't remember this. Please document this email or the contents of the package it attaches. After checking the email, I noticed that Lin Hobs informed Mike Granville and Rod Isme that she had discovered that Fujitsu can actually make an entry into a branch account remotely, yes, so you're saying that, in an email sent to you on December 5, 2010, they told you that it had been discovered that Fujitsu can make an entry into a branch account remotely, yes, so Lynn had told that to John and then to John.

She had forwarded me Lynn's email, so it's the equivalent of being given that information secondhand. Yes, does that make a difference? To the extent that he was bringing it to my attention for information. So I think it's something slightly different. I actually received it directly from you know how to act um, as I think I said here, this was something that I was not aware of and I had not been aware of previously and I actually don't remember receiving these emails um and I requested you know, office of emails, can I get my answer to this because I would and there isn't one?

There is none. um, I could put it this way. You received an email on December 5th that said in terms of Fujitsu actually being able to put an entry into an agreed branch account remotely, that's what Lin had left in her email, yes, let's try again. On December 5, 2010 you were provided with information that Fujitsu can actually put an entry into a remotely agreed branch account in that email train, yes. Thank you, can we turn to page 15 of your witness statements in paragraph 31 and you say that prior to 2011 you were not aware of the ability of Fujitsu employees to alter transaction data or data in branch accounts without the knowledge or consent of the subpostmasters? yes, yes, but that's not right, is it because they had told you about it in the email on December 5, but as I said, I don't remember seeing that in December, that's different if you now remember 14 years later receiving it? an email that you say in the witness statement here, you were not aware of the capacity, whereas in fact you were aware because you had been sent that email, but without seeing that email as part of this, you would not have made. knowledge, that's all I'm trying to say is that the first conscious knowledge of that was the Tracy Marshall email which would have been several weeks later, then the John Breeden email was, I think, December 5th and a month later, um this.

The information came from Tracy Marshall, so the lightbulb moment for you wasn't Breeden's email from December 2010, it was Marshal's email from January 2011. Yeah, okay, can we see the email? electronic playback 2010? So please poll page 308 8956. The first page is from Mr. Breeden for you and the copy for other people, yes, yes, and he forwards a string, um, if we look at the bottom of the page, uh , Miss Hobbs, do you remember who Miss Hobbs was?, uh, Linn Hobs, yes. and tell us oh I'm sorry, she was I think she was the general manager of the John Breeden support network at this time and I don't remember the change of responsibilities to me, but John Breeden would be reporting to Lynn and she had done that.

For quite some time, like Lyn Norbury and also Lynn Hobbs, I inform you indirectly, no, Lynn was older than me. I see it says, this is the last email exchange I have with Mike Granville about the business that complies with the attached documents or What Mike was proposing to Center Beers I haven't seen anything else, but I had a conversation with Mike about everything the topic of remote access to Horizon. He expressed the view that, while this may be possible, it is not something we have asked of Fujitsu. provide I don't know what the final result was.

I will also continue to forward two more emails, one from Rod Isme which is the final report he produced as a result of a request from David Smith and then through the page please, the second from Mike Griffi with a document that sent to Biz in August as a lead up to Ed Davy's meeting with jfsa so that's Mike Granville sorry Mike Granville yeah sorry you said Griffith then cut off Lyn Hobbs email is her response to Mike and Rod. saying that I discovered this week that Fujitsu can enter an entry into a branch account remotely came up when we were exploring solutions around a system generated issue after migrating to Horizon online.

This issue was quickly identified in a deployed solution, but affected around 60 branches and meant that a loss or profit incurred in a particular week disappeared from the system. One solution that was quickly ruled out due to integrity implications was for Fujitsu to remotely enter a value into a branch account to reintroduce the loss or missing loss. profit, so the post office can't do this, but Fujitsu can. I think you'll agree that this is very important information, right? Yes, but before this I would not have been aware of anything aboutThis, which makes it even more significant, no.

To the extent that this was something I wasn't aware of, I said and I don't remember seeing this and then looking at Lynn's note, which is a pretty strange note, the way she left this in an email chain, which seems quite strange to me. It's strange for us too because we can't find any record of it anywhere else. I've never seen an email like this before, where something gets cut off. Normally you would forward the email or attach it, so it seems really strange to me, but I think at this point, Lynn Lynn left the organization shortly after.

I think this was from seeing this. I think Lynn just handed things over to John before she left and John and I were coming onto my team. So I'm just taking a step. Back from this, this is an email chain that forwards you the correct Rod Isme report, yes, and at the same time forwards you the Rodisme report. It tells you something about MH remote access, yes, and the beginning and end part of this well that is cut. in is about remote access and a little bit in the middle is about the context in which the correct remote access came about, yes, so it says that there is a function to place entries in branch accounts remotely, it provides the context in which that problem came up 60 branches and a solution and how do we fix the error that occurred if we use this, no let's not use this remote access because it has integrity problems, but in any case Fujitsu can do this, yes that's what it tells you , yes it is.

Can we go back to paragraph 16 of your witness statement? Please, it's on page nine. Please scroll down. Please, you are dealing with the Isme report. It says here that although I don't remember receiving the report. I suppose its contents would have calmed me down. the moment you say some things about knowing what you know now, yes, and you say in the last three lines, in particular, the report says there is no backdoor, yes, yes, and then you lay out some information that you now know, so you are all saying that the content of the Isme report would have reassured you yes yes but I don't want to say I don't remember seeing that in December I definitely saw the Isme report I'm not sure when I thought about it it was a date after that, but we know that he received it on December 5, 2010 because we just looked at the email.

J yes, what I'm saying is that I don't remember it from that moment, but I do remember reading it. the report and I thought I had it separately um but not at the time that Rod put it together, which I think was in August um you say that would have calmed down and apparently it would have calmed down because the report said there was an absence backdoors yes, but the same email chain that brought this report to your attention said something very different, right? I'm not sure what's recorded is different. I think not, let's see what their reaction was separately.

Looking at the facts, you would agree that the same email chain that brought the Rodisme report to your attention said something very different about the lack of backdoors, wouldn't you? He didn't mention the rear doors, he said they could inject um. they could remotely control what Fujitsu could access remotely in injection transactions, so I think the backdoor part is quite different. I think, to me, the lack of backdoors seems like it's done in an uncontrolled way, whereas if they could inject, which I already know, later I learned about transaction balancing, which is that kind of scenario, then I think that for me the two are simply not, they are not the same for me, what is the difference?

So, as I say, I think the back door is, I think, in a more uncontrolled way, whereas the injection is done in a controlled way, so do you think you made that distinction at that time, probably not? It's you who rationalizes it now and because now I know more than me. I knew it then, so I guess at the time, like I said, I didn't do it. I don't remember getting that email from John, so he didn't check in with me at the time and the fact that Lynn, who was older, so just to put it in context, Lynn, so my direct report was at His Huggins. at the time Su and Lynn were partners, so Lynn was older than me, the fact that she had mentioned there that she had raised that it was Andy McLean who was again at that level but in him and I think Mark Bley was also project manager within that space, the fact that she had raised it and they were looking at it, but she didn't have an update, I mean, when I look back. that there was no sense of urgency in it that she would have expected if she had been truly concerned about what she had learned could happen.

Thanks, the significance of Mr. Isme saying that there were no backdoors to Horizon was that it meant that all data entry or acceptance was at the Branch level, correct, yes, and was tagged with the login ID from the user, right, yeah, and the importance of that was that the ownership of all the accounting was really at the Branch level, right, mhm, the email that we looked at. What he was saying was that ownership of accounting was not at the branch level, wasn't what he was saying that Fujitsu can inject transactions remotely and can alter it? Yes, doesn't that undermine in your mind what Mr.

Isme had said? I think the difference and I think this is The important thing for me was if something was injected into a branch accounts, it would be with the knowledge of the postmaster whose accounts they were and I think that's a really important aspect and email doesn't It said nothing about the knowledge of the postmaster. Did he do it? He did not say in any way whether they were aware or not. He wasn't saying that if we did it there would be integrity issues. Yeah, don't you think that was implying or suggesting that this was? everything is being done correctly with the knowledge of the subpostmasters.

I didn't really think about it at the time. Can we go back to email? Please poll 30 AG 8956, so this is the chain that sends you ism reports in December 2010, how good? Did you know that Rod is not feeling very well at the moment? So he was... we were part of the senior leadership team and we met periodically for conferences and things like that, but I would like to meet with him monthly, not knowing how often. He was frequently your contact. I wouldn't have met him in terms of the course of my role before this, so this was the first time, so taking on this role was the first time I really hit the ground running. with Chesterfield, which is where Rod was in charge of um Chesterfield um before that, I wouldn't have had much involvement with Rod at all, he was head of um product and branch accounting at the time which later became the service center financial, but yeah, and if we go to page two please, we can see that the email from um uh Lin Hob was to um Rod Isme originally yeah, because it's uh Mike and Rod's address and she has written on her own email my response to uh Mike and Rod, you say that I think this is a very strange way of writing emails.

Yes, cut and paste something into your own email instead of attaching that email or forwarding it. Yes, like I said, they haven't revealed it to us. There is no trace of um. email in mr ism's inbox, are you saying that at the time you would have considered it suspicious that this had happened? Yes, like I said. I don't remember seeing this. And that would have seemed really strange to me. I just find it to be a very strange way to do something because whatever and how I saw things during my time at the post office is that they forwarded the email to you or it was as an attachment so you had the whole chain of communication regarding anything. the theme of that was so, just getting back to it, so I think if I had seen this, this would have seemed really strange to me and that's why I think I didn't see it.

Are you saying you didn't see an email that was? I sent it to you, yeah, I don't remember, that's a different problem if you just go back to page one, whether it's been about 14 years or so, you can now remember that getting an email is a problem. MH, you were tending to suggest a moment ago that he didn't. I see this email yes, how can you now positively say that you did not see this email? So what I'm saying is that I don't remember seeing it and the fact that the way it's built is really strange and I think I would have remembered it at the time, because it seems really strange to me.

Did you read your emails? Yes, there would normally be some reason not to read an email. Work volume. What about one that deals with informing the sponsoring Department? Department of Business Innovation and Skills, so as I said, this was a new area of ​​work for me in that I hadn't been involved in this type of work before. I think December 5th, I think it was Sunday, because I looked. see why you know I haven't answered this, but I tended to. He used to read all my emails, but he also tended to reply to all my emails, um, and this is what I find really strange because I didn't.

In any case, I don't have an answer to this question. The um Isme report came to your attention in the context of a discussion about what had been said to the Department for Business Innovation and Skills in early 2010. Would you agree to look at it now? that Mr. Breeden's emails did not make clear whether he had informed the department about Fujitsu's ability to manipulate the branch's accounts. Yes, it wouldn't have been a very important issue for you to have gotten to the bottom of. I say at that moment. a new area for me and I wouldn't have given it much attention, so the people who would have been involved in that would be Mike Granvill, that was his role, and Sue Huggins, who was my boss and I think Mike Grandville.

He also informed Sue at one point, that was his area so it wouldn't have registered with me at the time, but there was a chance that the sole shareholder would have been told that the Post Office had a major problem on its hands. That is, your supplier could manipulate branch accounts. Yeah, wouldn't that be something you'd like to get to the bottom of? What did they tell the government? As I said at the time, this didn't register well. I don't believe it. I saw it but it didn't actually register because before this I want to say this is the first time I've gotten involved in anything to do with Horizon Integrity um before that, from the moment I feel it, that's the point I'm at. posing. is that it is in the context of the sole shareholder that the government is informed and therefore it is very important to know what the government has been told and what the true position of MH is and what it has told us today and what it has told us today and What he said in his witness statement is that there could be good reasons why there is no follow-up to this yes in the paper because Lin Hobs left the organization shortly after, yes or that was what had been dealt with.

I didn't see anything that came out after this that he told me. Well, actually, what happened to him? There was no problem. Was this dealt with offline? Not that I was aware of whether those conversations happened because I would have expected that the continuation of that would have happened with Lyn and Andy McLean, who says he referred to Mike Granville and also Mark Burley, so I'm not. aware of anything um as a result of this email package thank you can you download um the email as we have seen um referring to the context in which the remote access discovery was made remember the incident that had been discussed in a meeting that involved to 60 branches in October 2010 yes yes, can we see that survey please? 3028 38 this is the, I think, the only record we have of what happened or what was going to happen at that meeting in October 2010 and if we look at the list of attendees, I think we can see that there are six members of the office of emails present and are the first six on the list.

Yes, did you have responsibility for any of those? Can't. We turn to page three, please, sorry, not at that moment. I didn't do it, yes, not in December 2010 or January 2011. Can we please go to page three and scroll down? Can you see the proposals for how the bug would be addressed? relation to the affected branches and you can see in Solution one um Sol, the proposed solution was Al the branch figure on the counter to show the discrepancy. Fujitsu would have to manually write an entry value into the local branch account, the impact would be when the branch comes to complete the next trading period, they would have a discrepancy that they would have to take into account.

The risk was that this would have important data. integrity concerns and could lead to questions about tampering with the branch system. It could raise questions about how a discrepancy was caused, this solution could have moral implications of the post office changing branch data without informing the branch, would you agree that this record, although that solution was not adopted in hecase, first make it clear that Fujitsu could alter the branch accounts remotely? Yes and secondly, they could do it without the branch being able to see or know. Yes, did you talk to any of the six people on the attendee list after receiving Lyn Hobbs' email?

No, did any of those people later draw those two? Material Facts Fujitsu may alter branch accounts remotely and may do so without the branch being able to see or know for your attention. I would not agree that those two facts, if they had arisen, would have significantly undermined Horizon's reputation and integrity yes, at this time from October 2010 to January 2011, the post office was committed to maintaining Horizon's reputation, It is not like this? Don't know. I mean, I wasn't aware of this document until much later, in the Glo um, how did it happen that this additional record, in addition to the December 2010 email chain, didn't reach you?

What went wrong? Well, I think in 2010 then I wasn't involved in anything to do with um, Fujitsu or Horizon issues, I only started getting involved in 20, so there was the email from TR Tracy Marshall that was, um, before the meeting Ferndown which I attended and again I was the one who came into it because my boss Su Hugens. at the time I was on vacation and then we got to um Sho Smith's letters, uh, about the individual branches, so this is not my domain at all, but you were starting to investigate the integrity of Horizon in the late 2010s early 2011 right?

I went into analyzing these types of these types of issues before that. Wasn't it or was it that you and others within the post office carefully avoided lifting the lid on what had happened at the October 2010 meeting when the Not only was a receipt and payment discrepancy error discovered, but also Fujitsu's ability to manipulate branch accounts was revealed. I wasn't aware of this and I wish I had been aware at the time because that fundamentally changes what I understood. to do with the Horizon system and even just the language used here was clearly known and the fact and there is no escaping this in this document that they were consciously deciding what to do and what not to do and what not to share and that is tremendously alarming, thank you so that might be an appropriate time for our new system of two 10 minute breaks to take the first one can we say until 10 11 please yes indeed Mr Beer thank you thank you e e e e e e e e e e e e e e e e e e e e e e e So good morning, can you see and hear us?

Yes, thank you Miss Mader, can we turn to the second set of correspondents relevant to the topic? We have seen that you referred in your paragraph 19 to an email you received from Tracy Marshall dated January 5, 2011Can we upload that please survey 2947 28? Can you see at the top that it's an email dated January 5th to you and others from Tracy Marshall, yes, and her title was agent development manager. Can you explain what that was please? I don't really remember what I was doing at the time, what relationship it had with you and your work, um, not much, at that time, why was I writing to you?

So it was actually for Kevin, so I think Kevin had asked him. I think she was part of Kevin's team. I think Kevin had asked him to do something. I don't remember having any conversations with Tracy about this until I received the email. Do you know what the context was in which Kevin asked? It was the F Down meeting, so they asked me, like I said before, for 10 days. It wasn't something I would normally do, but Sue Huggins, who was my line manager at the time and reported to Kevin, was on holiday. so she asked me to intervene and the topic is Problems with the Horizon system and point two says two: the post office or Fujitsu has remote access to individual Horizon systems.

The first paragraph the post office cannot remotely access the systems or make changes. specific stock units, etc. Fujitsu can remotely access systems and do so on numerous occasions throughout the network to remediate GL's on the system created as a result of new software updates. Technically, Fujitsu could access an individual branch remotely and move however this has never happened, but the authority process required in the audit process is robust enough to prevent this activity from being carried out fraudulently. . The authority process itself would take several days and require multiple company representatives to provide consent to the activity, including the head of network services.

If a change were made remotely to an individual branch account, it would be flagged in the company data books and would appear as a discrepancy in the product and balance accounts in Chesterfield, pbna would then investigate to determine whether the discrepancy was authorized internally or not, although changes can be made remotely, they would be detected and the person making the change would be identified now that the

inquiry

has heard evidence suggesting that the claim that Fujitsu had never used its ability to access individual branches and move money around is incorrect, at the time you received this email, would knew no, the inquiries received evidence that the stroke audit process of the Authority's process to prevent the activity from occurring was not robust and that there was insufficient assurance that this was the case? it was not being used fraudulently at that time if he had received evidence to that effect.

No, the investigations heard evidence that Fujitsu sometimes used the user ID of a subpostmaster to inject transactions into branch accounts for standard arq data. produced subsequently failed to distinguish between injected transactions and those made at the branch did you know that at the time of receiving this email no, the investigation received evidence that Fujitsu had had unauthorized privileged user access and was unauditable if it had known of that? the time I received this email no or how long it had been in operation no and what concern had I had within Fujitsu that this privileged user access existed and was not regulated.

I had no knowledge of any of that. I was told that you need me to speak meaningfully please meaningfully okay thank you the month after I received this email sorry within the month I think it was the day after you interviewed Ms. Ratell , also in Old Street, London, yes, that's right. This was the Ferndown branch. what she was concerned with in the dorms, that's right, that's right and she was the deputy postmistress of that branch, right? Wasn't she? Can you summarize what had happened to Mrs. Aell, so I was not involved in what happened? From memory, there was a problem with the audit and it had been suspended.

The first time I realized and put this in my statement was when Lin Hobbs contacted me because my role at the time was to provide, as I said, network. service branches opening again but also providing mobile post office services and she asked me if I could provide her with a mobile post office outside this branch or near the branch if she needed me, that was the First I realized something which had to do with and I don't remember when it would have been a few months or before this because I don't remember when the audit and suspension took place, but that was the context.

I was aware that I knew it was high profile because Ly told me and I think Dave Smith was the CEO at the time and he had gotten involved. Paula would have been the director of the network at that time. I think that can be achieved, thank you. and the problem at Ferndown had involved an unexplained loss shown on a dant share unit. Remember? Yes, a relatively small amount of money. I think so. I think it was hundreds rather than 700 pounds. I think so. So, um, attend. uh this interview on Old Street can we see the transcript of the interview please uh po 29 4743 what was the purpose of the interview?

As I understand it, the relationship needed to be reestablished because I think as a result of um, suspension and some of the issues related to that that there was a breakdown in the relationship, so that's what I thought the purpose of the meeting was to reestablish. the relationship between the post office, on the one hand, and the submissive and the submissive mistress, well, ma'am. It was the subpoost mistress, but it was actually Val, her husband, who was the one who did most of the talking at the meeting and I understood at that moment that Val had been talking to the press and things like that, so, but basically it was for you know, then Ms.

Atwell had been reinstated and at this point and it was really just about reestablishing that relationship, which is what Kevin was looking to do if the purpose was to reestablish the relationship, why was the tape made of the meeting? Actually, I don't know because it wasn't typical for us to get involved, we would have recorded these types of meetings, I don't know, it was, and that would have been, I think probably at Kevin's house, I'm not sure if we wouldn't have done it. I really question it, if we look we can see the explanation given by Mr Gill Brand.

Thank you just for putting it on the record again. The purpose of recording the interview is to ensure that we have a factual record of the meeting we agreed to. The content of this meeting will remain confidential. The information discussed should not be shared with other parties unless express permission is given from all international attendees in this room and Mr. Athell says I have a problem with that. Yes, again, can you? You help us if you are trying to restore the relationship between husband and wife, postmaster team, um, why are you recording them like I said?

That wasn't my decision and it's something we normally didn't do. Normally we don't, the only time we would have recorded interviews is when it was one person from a post office perspective having a meeting with someone else, that's what we would normally do, otherwise we would take notes, so I don't know, I mean. I don't remember having any kind of conversation with Kevin about this, as I said I came into this because my boss was unavailable, so he wouldn't say I can't add anything else. I'm afraid we can scroll up and see who is present in the brand Mr Giller and you, Helen Rose, why was Helen Rose there?

So Helen Rose was part of the security team and I think she was an analyst. um and I'm not sure, I guess I'm not sure if I asked him or if Lynn had asked him to look at the information um so that we could establish what had happened in the branch and that was Helen's role and then Mr. Madam, well, and Mark Baker from the Federation, can we turn to page three please, to the top of the page and this is Mr. Baker speaking, so we've moved on from where we left off with Andy Bayfield when he did the appeal and accepted accepted during the interview that the initiation of the stock unit that had been closed for some months before that in you in use rat words came back to life with money in it she said that could only because of one of two ways and that was because a human physically made it within that Branch or it was generated by the computer itself for one reason or another and he was going to get to the bottom of that as far as I was concerned on the technical side.

That's where I'm still waiting to find out how this happened and that was accurate, wasn't it that Ms. Rell had been reinstated to Ms. Aell, but it was still a mystery how a dormant stock unit was closed, er, money? had suddenly appeared on him and there had to be some technical explanation or investigation for that, right? Yes, and you say AB, that's you. Helen has looked at the information in the records and taken that information and put it into a working file for herself. So she can because, as you can see, there is a lot of data that would be for that branch and they would put it there and they can track where that amount of money has moved through the system, in your branch, so she can talk to you about that and We can do that from time to time, Mr.

Baker, if we look at what you say in about four lines, it asks a question: was it something that someone did in the branch or was it something that the system did? Can you see that yes, I can? So if we can move forward please to page 11. I'm just reading this to give you a little context about what the issues are at the bottom of the page, about eight lines starting with item 152. Mr. Gilbran says well. we can point out where the figures come from that's not true we can point out where each figure comes from uh Mr.

Arol, can you manipulate those figures behind the scenes? Mr. Giller Brown, no, we can't, Mr. Well, no, you can't log into the system. Are you saying that Mr. Gilbran says no, we can't, Mr. Athell, no, you can't get into the systems? Answer no, Mr. Athell, you cannot log into the Horizon system. Mr. Gilbran, no, on the page, he says yes, you can and Mr. Gilbran says no, we. We can't, no, we can't and thenmessages. So for my part, this was about the balance transaction, which was the first formal acknowledgment I knew of the insertion of a transaction other than the Legacy system um, but it was the balance of the transaction that I knew had been used in March 2010 so when I answered the question that's what I had in my head what it was and that was I couldn't remember the date and I still don't know the date but it was leading up to the trial um I realized that was in actually something that happened, you used the word formally and actually in the answer you just gave in what sense were the communications of December 2010 and January 2011, the latter of which you took at face value, not formal communications or real of the position. because the position changed after that, as I understand it, we were asking and I never actually spoke to Fitsu about this and I never spoke to the guys directly in terms of Andy McLean's position was changing and therefore there were very messages strong statements coming from the post office that these things were not possible, so it was only when I had the balance in the transaction information confirmed that it actually registered for me that that was the formal position and there was evidence that I had taken place in March 2020, sorry March 2010, you were suggested to suggest here that you only learned about Fujitsu's ability to insert transactions in mid-2018, so this was in the last year or so, right? ?

Yeah, that would have been about um, I mean getting into my memory is getting into Glo prep, so working on that around 2017 would have been my memory, but I couldn't put a date on it and I still can't put a date on it. the balance in transaction, so why didn't you say well, wait? I received this. I was told about this in December 2010 or January 2011 because I think at that time I said the messages had been changing. I'm not that worried about the messages. more interested in the facts, that was my memory at the time, which was the balance of the transaction, which for me was that formal recognition by Fujitsu that this could be done simply as a secondary matter at this time in the paragraph 20 that may come.

In paragraph 230 23 of your witness statement you say that you remember discussions between the Post Office's legal team and possibly the Post Office's IT team, Fujitsu and Gareth Jenkins, in the course of preparing for civil litigation, but you were not involved. in those discussions and therefore cannot say to what extent Fujitsu or Mr. Jenkins provided assistance in the group's litigation. It's right? Can you confirm that you had no contact with either Mr Jenkins or Fujitsu in relation to the provision? from the witness statement you gave in the high court, so I think there were only two from there.

I think there could have been two, but there were, so I spoke up. I spoke to Gareth about the lepton issues. At the time Helen Rose was watching. that was when the events were happening, not in preparation for the GL um, that's true, yes, um, although Helen Rose's report was part of the Glo, so I don't remember if I spoke to Gareth again about that, sorry. Be clear, you can't remember if he spoke to Mr. Jenkins again. Yes, I'm not ready. I think so. I mean, no, no, I don't know Gareth Jenkins. I didn't know him.

I did it. some email correspondents I definitely remember him and I think I might have spoken to him maybe once or maybe twice but I don't remember the details so there was the um there was the one I spoke to and I had some correspondence with him about the lepon issue, but I think that was earlier and I'm not sure if I talked to him about Angela Burke's information. I don't remember if I spoke to him directly or not. Did you ever meet Gareth Jenkins? No, I never met Gareth Jenkins. Say that in um your um evidence under cross-examination in the Horizon emissions trial just for note um Fujitsu 0016 3744 page 25 um in paragraph 214 of your witness statement if um we find that please that's on page 101 101 by please page paragraph 214 you are dealing with your common problemswitness statement here and you say in the second line that for the most part this was derived from my own knowledge yes some of which will have been drawn from documents you have read throughout over the years and that did not arise from any conversation I had.

I had with Mr. Jenkins at that time, I'm sorry, I'm sorry, sir, the content of his common problems statements, so the majority of my common problems statement was more broadly about the post office and how it operated, yes , and then what about Horizon's trouble witness statement? All that. derived from Communications with I do not believe in conversations with Mr. Jenkins. No, I don't think he had a conversation. I don't remember, but I don't think I talked to GIS. Okay, thanks for coming. group litigation Were you asked to participate in any outreach exercises? No, that's what I remember, so they didn't ask her to look at his emails.

Oh, um, to find, for example, the December 5th email or the January 5th email. so I think the disclosure exercise was done within the business and everything was done that way. I don't remember being asked to go back and look at anything or look for anything on my laptop in particular, did you go back yourself? and look at your emails or other document repositories so that you can consider your state of knowledge on the issues relevant to the Horizon issues trial in order to prepare your witness statement or your AAL evidence. um no, so you didn't think that I'm going to be asked about Horizon Integrity.

I should look at my email account to see what I have received over time about Horizon Integrity so I can provide direct and open evidence. I never, ever looked back, I don't remember the emails from December. and I wouldn't even have known where to look for that ACC. I don't even remember receiving them and the search interview really was for me, it was less about the integrity of The Horizon and remote access, it was more about that. supporting Kevin in that meeting and it was about reestablishing the relationship, so I didn't enter the two tests. I didn't look through my emails about that and I would have forgotten about those emails anyway, but I said I don't even remember having John's, isn't that why, if you're testifying in a big case before the high court under oath, you could perform a self-reflection exercise and say: I'm going to go through my email and see what I knew when I wish I had known but I didn't, so you maintain that the emails we analyzed from December 2010 and on January 5, 2011 they were also not shown by the lawyers who were preparing their witness statement or found by you as part of an evidence preparation section yes, I don't remember, I mean, it was only at the beginning of this exercise that, um, I remember the phone being down, uh, having been involved in that at all. you carry out any self-reflection exercises on what you knew about active numbers in the Horizon problem test you search your own journals you search your own email email um inbox and sent items you review any notes you have made for the Horizon test yeah um so the biggest content for the promotion and the trial is that I got it from the investigations that my team had done on the cases.

I didn't do any again. I didn't do any searches on my uh, my laptop, um and in terms of my I can't remember the diary and why not, um, I don't know because I didn't think it was relevant in terms of what it was, the information that it gave me. they gave, I just didn't think about it and no one suggested anything. He told me that was something I should do when giving evidence today in preparation. It seems that you have investigated whether December 5th was a Sunday or not. Yes, why didn't he give that care and attention to the previous occasions when he gave evidence, so I think the difference with this investigative approach is that he had a list of documents to review.

I had a list of questions to consider and did as much research as I could, that was a very different approach. even when I present evidence in the two trials and I think looking back and going into this, I came into this knowing what else to expect and I made sure that they know that I have familiarized myself with everything that has been provided to me and requested more information when I believe that there was more. I didn't have the same approach in the two tests. Can we go back in time? um still looking at remote access and survey 0011 5919, this is um a briefing note, as we can see, prepared for Paula Venel in relation to the second site review at Horizon and in particular the implications of her interim report, her draft and indicating the second end of July 2013, if we look at the bottom of some page at the bottom of page two for a little context, please, I must say that this is all part of the background.

Keeping it brief for Miss Venel, paragraph 7 records that Susan Kryon, Leslie Su Elwin Lions, you and Simon Baker met. second site on July 1 at 3 p.m. to get a clearer picture of the provisional findings of the second site at the time of delivery, yes, so you already saw the second site the day before this document, okay, to find out what they are going to say. Basically, in their provisional findings they agreed. I don't remember it, but yeah, it's there and if we move forward, turn to page four. Under the heading, the two anomalies, the document says that we also understand that the second interim site report will discuss two anomalies in Horizon's operation that were found. by limited post office and voluntarily communicated to the second site.

I was also not identified by the second site as part of their review and then the first one is identified as the branch 62 anomaly. This is the receipt and payment discrepancy error, if you remember what was discussed at that meeting in the fall of 2010, in which it became apparent to six people at the post office, including Marwood Tundle and Win de Mess, that remote access was possible and allowed Fujitsu to manipulate branch accounts without the knowledge of a deputy postmaster and then a summary. is established um affects if we just read the first part A affects 62 branches refers to the discrepancy in receipts and payments um in Legacy Horizon um sorry in Horizon online when the discrepancies were moved to the local suspense account appeared first time in March 2010 most of the incidents occurred between August and October 2010 uh the losses varied from those two amounts um identified by Horizon's built-in checks and balances could have been identified if the subpostmaster had carefully examined his balance report final 17 branches were adversely affected subp sub poost Masters notified in March 2011 and, where applicable, the reimbursed deputy manager made a profit through the anomaly.

We are not asked to reimburse this prior separation. The separation would have been dealt with by Royal Male legal and then set out the reason for the delay in notifying the subpostmasters. and then about and then it goes on to the branch 14 anomaly which is something else yeah who was responsible for this branch 62 anomaly recap um I think it was Simon Baker who put it all together did you contribute to this ? I read it before I sent it to Miss Benolds. I don't remember. I don't remember seeing it before, but I can't be sure. Do you know why the remote access problem is not detected in this context?

No, right? I know why it doesn't reference what you knew was the result of the December 2010 emails and the January 2011 email, as I said. I don't remember the one from December 2010 anyway, but no, I just don't remember this at all. so Simon was putting this together, if I remember correctly, Simon was a part of it and he changed the space um and Simon would have been the best place to have that information, but I'm sorry, I can't, I can't answer anything more than that, right? we can continue? Then to 2014, please look at survey 0030 4439 and start by looking at page three.

There's an email from 2014, April 10, 2014, from him to Andrew Win and Alan Ler, so at that time I think he was the head of Partnerships. Is that so? Yes, we can see that in the footer. The mediation plan is in place now. Yes, the second site produced their report and you tell Allan and Andy as part of filing a mediation plan case. The applicant refers to an email. copy of which I am trying to locate has been mentioned in regards to this email quote with Andy win Allan lash's email in the Ward case, which explicitly states that Fujitsu can remotely change figures at branches without the knowledge of the deputy postmaster or authority and ask them, as a matter of urgency, to send you a copy of that email.

Associated emails and any other associated information, so you are asking them for a copy of the Win Lusher email. Basically, yes, yes, it's true, can we? Please look at the victory. Lusher send aemail to survey 01765 survey 011 7650 uh footer please scroll down a bit thank you Mr Lusher to Mr Win I spoke to you a few days ago about a suspension at rivm Hall by the page um I understood the problem correctly skip to the next paragraph um Mr. Ward, the deputy postmaster, stated that on several occasions the figures have appeared marked on the verification line of his account and he suspects that they have been entered into his account electronically without his knowledge or consent, you are sure that you have cleared and canceled the checks correctly and tell me that the checks must be cleared correctly in the system to move to a new account.

He has recovered around £10,000 and has not recovered approximately £. 1,000 of the shortages, he claims that due to the abnormal nature of these entries, the shortage has simply not been transferred from one branch business statement to another. The deputy postmaster's contract remains suspended and then the answer on page one please the only way to scroll up. Please, the only way the Post Office can affect branch accounts remotely is through the transaction correction process, these must be accepted by the branch in the same way as our remittances. I assume that if we could do this, the integrity of the system would be flawed.

Fujitsu has the ability to affect trademark registrations through the message store, but has extremely rigorous procedures to prevent adjustments from being made without prior authorization within the Fujitsu Post Office. These checks form the core of our judicial defense if we reach At that stage, he, who is the subpostmaster, makes a casual accusation that is extremely serious for business as usual. He should present evidence of this or drop the accusation. Can you see yes? That is the email you are looking for. Yes, right, can we? wow, please go back to survey 3439 and if we scroll down to page two, please, at the bottom of the page, um, Angela, find, attach an email that may be what I'm referring to.

I think it's that email we just referred to. um, I have records for a significant amount of documents, etc., would you like me to send it all to you at the top of the page? thanks, remote access by Fujitsu was possible from Andy Winds. Note: Yes, did you reveal that to the high court when you presented evidence? Don't think I did it. Did you forget this too? So I think I've brought it up internally. to get to the bottom of it, but I don't remember, but you told the high court that you only learned about the possibility of inserting transactions about a year before you presented evidence.

So far we've looked at December 2010, January 2011 and now a series of emails from April 2014 telling you about that agreed upon service, as I said the balance on the transaction was the first formal notification I remember having been informed before that there were several and you are absolutely right in the emails. um, but I did and in Andy's win I did something that I can't remember exactly what in terms of getting under the skin of it because there just seemed to be a number of almost throwaway lines in Horizon Integrity or things like that that just weren't being brought to light. and it was the balance of the transaction for me the first time that was proof that it existed and had actually been used, so I'm not sure exactly what I mean when I give my evidence to trials. it was based on what I understood to be true at that time it will be like December 2010 I just don't remember and there are things that I will have forgotten but there are things that have happened from some of the information shown, I just can't remember exactly which was the result of that, so could we take our second break in the morning?

Oh please yes, can I check the exact time? Can we meet at 25 please, yes, certainly and um. Could you think about continuing to say about the first trimester because if we only have an afternoon break it's probably better if we have lunch a little later thank you sir yes ok e e e e e e e e e e e e e e e e e e e e e e e uh good morning Siri good afternoon sir can you see and hear us yes I can Thank you, Miss Bogar, we were looking at the email exchange from April 10, 2014, where you were tracking down a copy of Win Lusher.

Email exchange, yes, can we look please? survey 34478 and if we look at the first page we can see that we are now on May 9th and there is a complete thread submitted by Andrew Parsons yes yes um if we can look at the thread please to see what is in it um and start on the page um six, please, and if we scroll to the bottom, we'll see an email from um rodri Williams on April 14 to um, uh, James, um Davidson at Fujitsu, yes, yes, uh, James, could Fujitsu please Please answer the questions? below so we can respond to a specific challenge brought to us by a second site regarding a mediation complaint.

Explicitly cite the winner's email in the Ward case. It states that Fujitsu can remotely change figures at branches without the knowledge or authority of the deputy postmaster and attaches Win Lasher's email. The part of the email in question is on the page. Fujitsu has the ability to affect branch records through the message store, but has extremely rigorous procedures in place to prevent adjustments from being made without prior authorization within the Post Office and Fujitsu. These checks form the core of our legal defense if we get to that stage and then Mr Williams raises a series of questions: can the post office change transaction details? without a sub postmaster being aware of the change, can Fujitsu do it otherwise?

Where is the evidence for this conclusion? If so, how does it happen? Why was this functionality incorporated? Why would Fujitsu need to use this functionality? What controls are there to avoid? unauthorized use of this access method when branch data has been accessed in this way in relation to Win Luxer email what is the message store? Can it be used to access and change branch accounts? What is the impact of this change on the branch accounts? postmaster be aware of the change why would this access method be used what controls are in place to prevent misuse of this access method um all the penetrating questions do you agree?

Yes and they necessarily arise from the two lines in Win Lusher. email that we have seen, are logical questions that arise from it and can we go to page four in the middle of page p? Mr Davidson or Fujitsu respond to Mr Williams see response below and then if we go two that's it C Fujitsu changes branch transaction data um uh without a sub postmaster being aware of the change response once created. The branch transaction data cannot be changed and then additional data can only be inserted if this is necessary. Additional transactions would be visible. on business statements, but would not require acknowledgment or approval by a subpostmaster, approval is granted by the post office through the change process in response to a previous inquiry that Fujitsu verified last year when this was done in Horizon online and we only found one occurrence in March 2010, which was early in the Horizon online pilot and was covered by an appropriate change request for the old Horizon.

A detailed examination of the archival data would have to be performed to analyze this access. I'm sorry. Examine this throughout the useful life. This would be a significant and complex exercise to undertake um and uh discussed uh previously with the post office but dismissed as too expensive um and impractical and then

gives

a series of answers which I'm not going to read to Mr Williams questions 4 a to e and five a to f , then we can go, sorry before we go any further, would you agree that this is Fujitsu saying that Fujitsu can insert branch transaction data, yes, and this is Fujitsu saying that Fujitsu could do it without the approval of a deputy postmaster Yes, they refer to the equilibrium transaction.

All this does not specifically say that here you believe that it is essentially about balancing transactions. I think so, can we go to page two please, at the bottom of the page? Mr. Williams says it is. producing a first draft of the note, uh, noting that he has intentionally not referred to Win Lusher's email, as it distracts from what would otherwise be a very clear picture. He hopes this will clarify the matter and not require referral to the task force. yeah, and then, um, page one, please, you're given the entire string and the tentative or proposed tentative answer to the second site's question, um, about whether it's possible for anyone to access Horizon Horizon online and modify the transaction data without the knowledge of the subpostmaster or his second line staff there is no functionality in the Horizon system, either through a front end terminal or a backend server, to edit or delete transaction data once have been transmitted from a branch to the central branch data center.

This is transferred encrypted to the branch data center and stored on a separate audit server where they are sealed using industry standard secure protocols to ensure data integrity, although additional transactions may be entered into branch accounts. , an assistant postmaster will always have visibility into these additional transactions as they occur. They are shown separately in the branch accounts. A more detailed note will follow. Did you approve this fallback response and move it to the second site? I didn't approve it, why did I send it to you to pass it on, but I regret passing it on? Think about the second site.

I think so. So I tended to move things to the second site at the time of the report. Can you keep your voice up? Please im sorry. I tended to pass things to second place at that time. information, but back to what you have, I mean what this doesn't say, it doesn't mention the balance in the transaction, um, looking at this now, I should have mentioned the balance in the transaction, you're ahead of me, the things that no sorry, it doesn't state that Fujitsu had confirmed that Fujitsu could insert additional transaction data outside of the transaction action.

Corrections, right? Yes, it does and that did not require the approval or acknowledgment of the subpostmaster. Does not say. that no, no, it did not inform the second site that the post office could not address the scope of any use of remote access in Legacy Horizon, something that has been used for 10 years because a detailed examination of the archival data was necessary. necessary and that would be expensive and impractical. It do not says that. No. No. Can you explain why the post office decided not to include those three pieces of information? Don't know. I mean, it says more detailed information.

A note will follow, but it won't be ready before the data file, but based on that, I don't know what additional work Andy expected to be done on this because just by reading you know what we just did. It happened even though I'm sorry, James Davidson, I think it was, you didn't actually mention the balancing transaction by name, that's what I took from reading this, um, but at the time I wouldn't have known about a balancing transaction. balance, so I know. subsequently and we should have included it in this and I think I just forwarded this to the second site as that is our position at the moment hoping for something else to follow but I don't know how you agree with that. um, the response drafted by Mr.

Parsons compared to the information provided by Fujitsu is materially incomplete. Yes, can we please continue to survey 3091 1394? Can we start with page two? It's October 2014. Now we're just looking at the footer, one for context, an email from Jessica Parker to a wide range of people, including you, it's about one of the cases that has been referred to mediation, yes, the second m53 site has posted a revised version of their draft. crr for m53, can you remember what crrs were? Case review report, so the second site's research into the applications of the scheme, so it's essentially a draft of what the second site proposes to say about an individual case, that's right, that's right, just read the rest. of that to yourself because it's not completely material if we go back to page one, please, halfway down the page, uh Belinda Crow, what role were you playing in late 2014?

So Belinda was the program director for the Sparrow project, she was also the Secretary of um, the working group, the scheme working group, and she asked the question: this is the first, are you the first What does it refer to remote access? I think we need to address this very, very robustly in our response as it could become public and the second site seemed like I'll be asking.proof that something did not happen. Could we dust off our lines on this and then if we scroll up the page please? Melanie Corfield, late 2014, what role was she playing?

She was part of the communications team, so she is a media and Communications, yes, expert or professional, yes, she responds to the same group, including you, our current line, if we are asked about using remote access to change data or Branch transactions, simply put, this is not possible and has never been possible, you knew it was false. from multiple sources you didn't already know, um, yeah, because what we just saw was injecting transactions into the branch balance in the transaction. We have the email from 2010 that, um, you don't remember, we received on January 20, 2011. I have the previous exchanges in April and May of 2014, that first statement this is not and has never been possible is false, which speaks to a change in branch data.

Yes, I think that's overkill, I mean, I'm talking about inserting a transaction. I'm not sure what I mean, that's what changing branch data and transactions says. You'd like a post office line to dance on the head of a pin. No? I wouldn't, which I think is what you were doing a moment ago. No? I'm just trying to entertain the possibility that, because this isn't about injecting new data, I guess I'm just trying to rationalize why you know that's been said when what we just came out of is the balance in the transaction um information continues uh this line remains, but if we are pressed on the second site's points about admitting that there is remote access, we can say that there is no remote access for individual branch transactions, you knew that was also false from multiple sources.

You are not sorry? Can we just send you James Davidson's email? What date was on that email from Davidson? It was May 9, 2014. Yes, sorry. Your original question was that I knew this was false. I knew that line doesn't exist. remote access for individual branch account BR transactions on the back of James Davidson's email and I was clearly aware of that and I just didn't understand this eh, Miss Corfield continues, we may get more pressure and the media will ask us to To confirm whether there is remote access or not, we will need to make the distinction between accesses as simple as possible, so we suggest no remote access for individual branch transactions.

Fujitsu has support access to the back-end of the system using software updates and maintenance, this is of course strictly controlled with security processes in place, but under no circumstances can it be used for individual branch transactions. There is no facility within the system for this. You knew that was false too, right? It wasn't recorded at the time, but obviously from what we've discussed, this is incorrect in terms of information flow. Yeah, so the three lines that appear to be a lead line in paragraph one and a press line in um. paragraph two and then, if they were actually included in paragraph three, all three contained statements that you knew were false, right?

Although I didn't recognize it at the time, yes, did you do anything to correct these three false lines? I don't remember, but I notice we have Rod and Andy Parsons here too. Sorry, I don't remember if anything else came of this. Mr. Barson's time will come in due time. I asked At that time, I'm sorry, my response was: I don't remember well. Can you help us? We have seen a large number of emails informing you in one way or another about Fujitsu's possibilities to remotely access and change individual transactions in branch accounts. When inserting data, why don't you raise your hand and say wait?

This is all wrong. What we propose to say. I just can't remember it. It just couldn't have registered with me in terms of the flow. of information that had appeared before, as I said, the message was constantly changing, but on the back of James Davidson's email I think you know which one came from Fujitsu, other information that comes from within the company or from different sources, but that came from Fujitsu and therefore that to me should have recorded as that and even though you know the note that Andy prepared, it should have recorded that that's what Fitsu was saying.

It could happen, that is the balance in transactions, if we just scroll. down a little thank you uh Belinda Crow says I think we need to pick up on this, that's the remote access suggestion very strongly in our response, as this could become public, is that the reason you didn't pick up on any of this and said Wait, there are three false statements, the only statements we propose to make are each false. F no, because the company wanted to respond firmly. I wouldn't have done it, I just didn't do it. If he had checked in with me, I would have questioned him. that, um, because you know we had one of the plan applicants, which is what triggered all of this anyway, which was already in the public domain because we weren't openly in the public domain, but we were already trying. with that then if that's our position we should have been saying that and I must have missed it it's you and a lot of other people isn't it in terms of who's missing it?

Is that what you're saying, yes, and I, well, is it a case of everyone's missing it or is the primary objective is to defend very strongly the position that there is no remote access, that was never my position, I want I mean, if I came I came into the plan originally at the beginning to get under the skin of whether there was any substance to the claims um and I spoke about that role voluntarily in addition to the day job I was doing at the time because I really wanted to understand that there is no way to that if ID thought there was something in it that I would have, I certainly wasn't trying to cover it all up or suppress it or do anything along those lines and that's what I'm struggling with because it wasn't just me who Are there other people who separate themselves from the same information at that time?

Thank you.you can come down can we move on to next year and then 2015 still dealing with remote access and look at the survey trip 08 9010 just give me a moment while I catch up on my work. That is, as you can see at the top. a briefing for you regarding an internal F film regarding Panorama, it ties in to give you some context, uh, with the BBC Panorama episode that was called dating problem at the post office, remember that yes, I do and that it was finally transmitted on August 17, 2015 yes, the document itself is not dated, but Mel Corfield sent it, we can know it from other evidence, by email on June 18, 2015, it is well, okay, if we just get familiar with it because I don't think we've seen this before: a film to use through the internal channel throughout the company to convey key messages and facts about the accusations that are likely to be made on the Panorama program of the BBC together with and supplemented by complete internal communications. plan currently in development um, although it is an internal film, it will of course be public, so it will be available to external audiences, it will be three to five minutes of hard-hitting questions and an answer session between you and Kim Fletcher from Bronswick Brunswick, a medium and an audience. relationship consulting yes, so this was going to be a question and answer session where the media and communications people at Bronswick asked you hard-hitting questions, yes, and you answered them, and if this was primarily intended for consumption internal, it's true, that was the intention, yes. uh, while we focus on some key rebuttals regarding Panorama's content, this message should probably address concerns or questions from a network perspective so that people feel safe, read the post office's position with peace of mind regarding to the system and, more importantly, they will be kept well informed. some poster publications in other communication materials.

We appreciate your guidance on network messaging on this topic. Panorama, you will have seen the latest email sent on Fridays. Friday's topic appears to be an accusation of a possible miscarriage of just jce miscarriages of Justice through inappropriate conduct on the part of the post office, especially regarding the alleged quote-unquote pressure on postmasters to that they will plead guilty to falsifying accounting focusing on three criminal cases Joe Hamilton and Thomas and aspects of Sea Misra that they will likely try to cite illustrate broader allegations. and which, of course, will provide significant human interest. The key aspect of this will probably be the accusations to try to create the perception that people were prosecuted for obtaining a model and for the recovery of money which will probably be largely concerned.

Reports from the second site cite as evidence that they are likely to have contributors who will continue to cite discarded opinions about Horizon through quotes from technical opinions, alleged revelations, final quotes about aspects of the system that are likely to include at least one hack in the program and that We might be on the subject of alleged remote access, but there are indications that there will also be selectively leaked material that will be used out of context and is likely to include accusations that the post office has not carried out the mediation plan fairly. and has hindered it. to avoid the risk of compensation.

I'm not going to read the rest of that page. Can we go to page three? Please, the key messages. Could you understand that these are the key messages you need to spread as written? um number one uh this is about missing money that we have a duty to protect uh trust is vital we have a duty to protect the money in our branches if the cash is lost and this is covered up we must investigate and act accordingly, we don't t prosecute people for making mistakes that we have never made and will never make prosecutions are very rare and only in light of all the available evidence and um circumstances um then the second key message: we do not control the legal process if we prosecute this is done with numerous checks and balances ultimately vetted by defense attorneys and the courts themselves, we do not charge or prosecute without evidence and we do not pressure anyone regarding their plea of ​​charges, the decision to plead guilty or not guilty is always the responsibility of the accused .

Only after receiving advice, criminal cases are kept under continuous review, that is our absolute duty. In none of our investigations or through that of independent accountants has any evidence emerged to suggest that a conviction is unsafe. We will return this afternoon to the fact that such matters cannot be evaluated. in the media about partial information often inaccurate nor should those two messages under any circumstances be um this is about lost money stolen by some postmasters and we the post office do not control the legal process their lawyers defenders and the courts, yes they did. You understand that in mid-2015 they were the key messages that the post office wanted to disseminate.

I hadn't seen it all together in one place. But since this was put together as a briefing document for me, then yes, the third one. The key message is that there is nothing wrong with the computer system, so before we ask you about that, if we just scroll up please, and again, this is about missing money that we have a duty to protect, we hear evidence earlier this week from Susan Kryon. um the general postal council and she told the president that you were among a group of people who had been at the post office for a long time and who thought that this was public money that was being stolen and that it was necessary . to be protected and needed to be recovered through prosecutions is that right, um in terms of taxpayer money.

I was always aware that this is taxpayers' money when I walked into the post office so that was a consideration and therefore we had a duty to spot that and make sure we had the right controls in place at Place Recovery through processing, that wouldn't have been on my radar at all, so it was really about from an operational perspective, just having the consideration and it was always a consideration actually that this is taxpayer money and not just in the context of support of the Master but as a business as a whole. Miss Kryon um held or seemed to hold the opinion that a group of people who were particularly long in the service, a group that included you. that you emphasized this point rather than it being simply a fact or issue as you described it today, which is part of the background, it is something where you emphasize that this is public money that we have a duty to protect, no, I never will I remember having done that, like I said, um, I had been in thebusiness for a long time, I had worked, I had started working in a branch and it was always part of the consideration that we were not well, we were shareholders, it was the government, but we. we were in that kind of quasi state where we were also required to make a profit, but we should have consideration for taxpayer money, but not against, you know, like it was a real emphasis against anything else, um, it wasn't.

Let it all end is what I'm trying to say, it was a consideration and I don't remember emphasizing that to Susan or anyone else, I mean, Kevin was Network, he had been in the business, I think longer than me, actually. um. and there would be other people in the network who would have been around as long as me or even longer, but I don't remember it ever being emphasized, but it was a consideration that there was no long service clique in the ranks initiated. like Count Clarks or the like who believed that this was just subtitles with their hands in the box for nothing, not at all, I mean my position.

I had worked very closely with the postmasters for several years, um and you know, I said on several occasions in the organization where people thought that the postmasters had their hand in the queue is that, in my opinion, the Postmasters were some people's honest workers and they did not come to the post office to defraud, that was not the reason they came. At the post office it was just the opposite. They came to serve the communities in which they lived. Can we go back to the third key message at the bottom of the page? There is nothing wrong with the computer system.

We have never said. Horizon is perfect or infallible, it is a computer system, so of course things can go wrong, but these are facts, not theories, and there is not a single example of

horizon

causing losses in any of the cases we we have examined exhaustively over the past few years. I have reviewed all of these cases and I have looked at all the facts, meaning all the facts, not just Horizon Records on the page, what we found and what the independent accountants who reviewed the cases found is that most of the losses. uh it was due to human error and unfortunately some was due to dishonesty we can't escape that.

What you thought was the result of the initial second site investigation and mediation plan. Well, our investigations did not find that there was any evidence that the losses were caused by the Horizon system and that is what the second site concluded as well um and some of them would have been the majority of the losses um I can't, I don't remember any of them. We sometimes pointed out dishonesty, but it would have been one of the possible results of the investigations, but I think coming back to this, this is a summary that has been prepared for me.

I can't remember, I can't remember what we did as a result of this because I tried to get it. any additional disclosure to say if we filmed because I don't remember, certainly the movie didn't come out um, but having a summary prepared for me, I would have, if I was going to use this, I would have adjusted it to one. how I speak and if there is any correction in the facts, then I would have corrected it. Can we turn to page seven please and scroll down to the main heading, second SES evidence? This is part of the report addressing the main allegations that Miss Corfield believes would be made by Panorama and the suggested responses are evidence from second sites that remote access to branch data is possible despite denials from the post Office.

These are facts, not theories. Many inaccurate things have been said in the media about remote access, but there is not a single example in these cases of Horizon causing losses, whether through remote manipulation or anything else more important. The point is sometimes lost in the technical explanations, once the branch records a transaction, you can't remotely change everything that happens. leaves a footprint of fo, so there is an audit trail that shows every keystroke, every transaction, everything that happened, we have analyzed all of that, of course, we have corrections and transaction acknowledgments and the other tools necessary to ensure that branches can remain in balance, but these must be accepted by the branch and make no changes to the original transactions, are recorded separately, the systems are independently audited and managed and meet or exceed industry accreditations, regardless from the state of knowledge of the post office, would you accept that this?

The response to the allegation about remote access doesn't actually address whether remote access is possible. No, it is not. I mean, I think you said this was in 2015, isn't it June 2015? Oh yeah, June 18, 2015, yeah, okay, no, it's it's, it's kind of a skirt around things, it's a side step, isn't it, yeah, it is, do you know why Sid does it?

gives

? I think this is because he has been put together by a communications person. Why does a communications person want us? step I don't need the main accusation, so I'm not necessarily saying that they would want to do that or that they intended to do it, it's just that if I had written this myself, I would have used different language and pointed out different things because in the mix of all of this we had the scheme case um that was the Brachel problem that Ron and Ian had been trying to get to the bottom of um and they hadn't, so you know, there were problems in the scheme that we were dealing with, so that this is different.

I would have written this differently in mid-2015. Was it the post office's position that it is best to avoid directly answering the question of whether remote access was possible because it will open us up to further scrutiny? I don't think so because we did, um, we did an interview with Panorama around this time as well, um, sorry, a meeting that we had recorded, so you know slightly different language that we used in that um, so I don't answer. your question no, I don't think it was, lastly, on the issue of remote access, so in your witness statement there is paragraph 16 1, you say that you were engaged in the registration of subpostmasters with respect to research issues in the mediation scheme, everything continues as usual. queries and other general queries within the Post Office relating to subpoost Masters and where concerns are related to remote access issues, the Post Office had pre-approved wording for what you were going to say.

Yes, can we please look at the documents you are referring to? the pre-approved wording of what you were going to say um survey 302 2659 um it's an email from um Amy Prime of Bon Dickinson but then a trainee uh among others you in July 2016 um please find attached the revised remote access text for your review, uh, we will provide any comments the Council may have on this wording in due course, this appears to be provided in the context of the response to the letter of complaint, that's right, as I understand it, yes, so the people who were to become Glo, the plaintiffs had written through free lawyers a letter of claim, yes, and this is part of the process by which the response to that was being constructed, it is true, you, in your statement as witness, said that the post office had a pre-approved wording of What was he going to say to the subpostmasters or within the mediation scheme or within any usual question about remote access? that this document that we are about to see had been developed by the Post Office before being distributed on July 27, 2016.

No, I am not saying that what I was trying to do with the witness statement is something like giving a sample of the strong messages that were coming from Paul throughout my time, um in terms of uh Horizon and remote access, so, um, so, no, I'm not saying, I'm not saying that in regards to this, can we look at the attachment please, which one? is survey 302 2665, as we can see that it is an additional clause, that is, something to include in the response to the complaint letter, response to the factual allegation that Horizon does not record transactions accurately and that the entire office mail has been U When you manipulate the Horizon data, you will see what is established.

I'm not going to give you the time. Read it carefully. Are you saying we should understand that what was stated here was a pre-approved wording by the post office of what you were supposed to do? Say before this document was produced. No, I'm not sorry, I didn't mean that and I apologize for how it was taken, but this document, um, in the information within the document will have and it was drawn from information within the organization that, um, we. 'I had had it over time, um, and it had been checked and I think if I remember this correctly, there was more sense checking to be done on the back of this note, so I don't think this was the absolute final version. um, but it wasn't pre-approved wording, but it's something that the information comes from within the organization.

Can we just look at your witness statement and then please, on page 80, page 80 and paragraph 161 at the bottom, you say? regarding concerns raised by subpostmasters from 2012 onwards, this would normally have been the person who would liaise with the subpostmasters, for example investigating issues raised as part of the scheme, dealing with usual queries, those raised outside of the plan and after the closure plan and dealing with general queries related to subpostmasters and then this with concerns related to remote access issues, the post office had previously approved the wording of what we were going to say, for example C and you cross-reference the two documents I just showed you. which confirms the wording approved in July 2016.

You have already told us that what we see in the July 2016 document is not the approved wording that would have been given before. Yeah, where are these post office approved wordings that were given? from 2012 onwards, as far as what you were going to say about remote access, that would have been in the communication messages, what do you mean by that? Mr Mand Boer, we have analyzed a series of direct emails we sent you setting out what I told you about remote access from 2010. You seem to be suggesting here that, on the contrary, the post office was giving you texts pre-approved texts on what to say and I ask him where the pre-approved texts are, so what am I?

What I'm trying to say is there's the information that we walked through today this morning, some of which I remember, some of which I don't and I think I said that, um, and then there was a There was a constant message from the company about remote access and Horizon and this is, you know, these are the lines that have been approved by the company for us to use so there was a constant use of messages about what I should say uh and to be consistent, but what we've seen here obviously in terms of the way we've gone through this today is the disconnect between a number of things that I've seen that clearly haven't registered.

In terms of the message in parallel to that is that you did not want to register the disconnection since you said no, absolutely not and that instead you were part of the message, right? This was not something that was happening. for you it was something that was caused by you. No, I don't think so, so I don't have the technical expertise in this and so I was getting a lot of this myself, um. that's why it hasn't been recorded on a few occasions and where it has been changed, the message has been changing because it's coming from a different source, so I wasn't at all trying to manipulate this in any way, quite the opposite, but as you said : "You know, I've missed some things coming here." Can you point to a single email or other communication in which you correct any message that says "no remote access or no remote access that a subpostmaster doesn't know about?" You can repeat it?

I'm sorry if. Can you point to a single email or other communication from you that corrects the message that says there is no remote access or that there is no remote access and a sub-postmaster won't know? I don't believe it. I don't remember sending an email like that, so it's already 10 pass one. I'm about to move on to another topic, namely errors, errors and defects, of course, yes, could we say five to two, please, yes, very good, thank you very much us sir yes can I thank you good afternoon miss vandon bogar can you um return to the topic of uh errors, errors and defects please open your witness statement on page 13 at the bottom of the page and you say in paragraph 29 that the first time I remember formally learning about errors and defects in the bases of the Horizon it system, although this was not the term used at the time, it was when the post office revealed to the second site two anomalies: the problem of mismatch of receipts, receipts and payments and the problem of the local suspense account that were detailed in the interim report of July 8, 2013 andthen in paragraph 30 of the page, please, the first few lines before this.

I was aware of the general rumors of complaints and concerns about Horizon Integrity and when it assumed responsibility for the contract management team, I became aware of the complaints. The Horizon system itself was creating discrepancies in the branches. So, going back to paragraph 29 at the bottom of the page, what did you mean by becoming a formal appointment? aware, so in terms of the bugs themselves, that was the first time I realized, I say formally aware, it's just that you know, I said Rumblings, so I was aware that people were claiming that there might be something wrong with the system, but It was only when those two errors were revealed that I realized the errors, but we have already looked into them.

I don't want to go back to that unless we have to do it in the email from December 2010. Yes, through the email that was notified to you. the discrepancy error between receipts and payments, so they notified me in December 2010, December 2010, no, I don't remember, so, some receipts, then the document that they took me to, which was the record of the discussion, no I knew it. of that at that time we can look please in the survey 30 8 8956 um second page um, the remote access problem, the second line of the quote came up when we were exploring solutions around a system generated problem after a migration to Horizon online.

The issue was quickly identified and the effect was fixed but it affected around 60 branches which meant a loss and profit incurred in one particular week, in effect it disappeared from the system but as I said I don't remember seeing this at all . For me, the first time I heard bugs or bugs or flaws or whatever words were being used was when they were disclosed back to the second site as part of that work. Are you closing your mind to receiving this information because you know how difficult it is? believe for you no, not at all, I would if I had seen this and remembered seeing it.

It certainly would have been part of my Consciousness in the future. I really can't see. I remember seeing this at all and it was the first time. when Simon Baker produced those two anomalies as he called them, um, that can come down, thank you, weren't you aware of that at the time? So, I mean, in October 2010, um Fujitsu um formally notified the post office about the receipts and the mismatch in payments, Mar, it wasn't there. aware that the cross reference so you don't need to show it is fuj 30817 didn't you know at the time it happened again in october 201 10 at a meeting?

I showed you the agenda or plan for the meeting earlier. between the post office in Fujitsu to discuss the discrepancy error between receipts and payments. I wasn't aware of that, sorry, sorry, I wasn't aware. I said I was in a different role in October, um, it was just when I came into the uh. head of network services role that brought Lyn and John, which I started to get involved at that time, so you were not aware of the provision of notes on the receipt and payment discrepancy error to members of the legal team, the polo legal team, um John El.

Singh Rob Wilson and Julian mcfar McFarland no, in the context of the sea. In my case, no, you didn't know about it at the time. It was much later that I heard about the sea. In my case, did you know that a meeting was organized in November? 2010, including Dave hbert Mark Weaver Mark Burley Rod isay Dave King Russell Ian will bring Emma Langfield Lynn Hobs and Anita Taylor to discuss how to resolve discrepancies generated by branches or in branches due to receipt and payment mismatch error, no, no I think so, this was all very important new news for you in mid-2013, it is true in terms of the beds that were disclosed, yes, but were you aware at that time, in mid-2013, of any discussion within post office senior management?

To what extent within the organization had knowledge of the three-year-old payments and the mismatch B not in the publication of the second site report, did you try to determine when the post office first became aware of that error ? report that the two errors were included in the interim report we are talking about, wait, no, did you try to determine which departments or which people within the post office knew about that error, no, why not, because the way they showed up was that, um, we? I have these two errors, so it was a surprise to me, and they assured me that it's routine, we've fixed them, it's been fixed, and I didn't.

I didn't push any further, you know? that the suspense account errors, which is the second of the two errors that you say the post office made a disclosure about on the second site, were in fact discovered by the post office in February 2012 before that Fujitsu would not ask similar questions again um What did we know about this error? When did we first realize it? At what level within the organization did the knowledge reach? No, in fact the second site mentioned a third bug as well as the calendar square and ferk or ferk bug that we were known to have. evidence from the post office back in 2006, the cross reference for that is fuj 308 3721, no need to show it, that was your first knowledge of it from reading the second site report, um, I don't remember, so it was the two errors that were revealed were my first knowledge.

I was aware of the third one because there is some crossover in what has been revealed and I was asking why we had only given it a second site if we already knew about a third, but I didn't know. About that third at that time, if it were really the case that the site's second report revealed three errors that you personally weren't aware of, you would surely have wanted to know how that had happened, so for the third one I did. Question, how come we only now realized that there is a third party and we hadn't done so at the time?

Because if we had realized and I was not involved in these conversations, but if we had realized that there were two errors that we had and we revealed them, then surely at that time we should have asked if there were more, but I was not involved in those discussions, there was some sort of um post mortem um that examined when the post office knew corporately. about these errors for the first time and what was done with the knowledge that we did not have and that I did not know at the time, so the information that came in was given to the second site.

I'm not sure if there's anything else, I think I've seen something since then in the disclosure that said we did something, but I don't remember I wasn't involved in those conversations, what was your role at the time of the first second site report? , so you had been working together? Ron mostly and Ian do reviews on the spot, so my role was really to facilitate the provision of information to Ron that they needed and that's what I was doing, going into the business to find out where the information was that we needed for that. By doing that, I was also looking at the situations myself, that's why I got involved in the Lepon case, uh, the Lepon case and I understood what had gone wrong in that case.

Were you the leader of the post office? Sorry, the leader. Yes, were you the leader? in the engagement with the second site, not the leader, I was there to help them in terms of giving them information, who was the leader in terms of the engagement with the second site, well, in terms of um, they were hired by um Alice Pauler um and Susan um. was there at the time so it really was Susan in terms of overall leadership, I would have said that, but you say she was in charge or responsible for the supply of information to the second site from the post office, not formally.

I was there to help. they, um, but who was in charge of providing information. I don't know if we ever defined that, because in the beginning, this is all the commitment of the second site and the initial investigation and then in the outline on which it evolved. time um and even when we started on the outline we were developing it in the working group as we went along so I don't think there was anything, any role defined at the beginning at the moment, this is before.July 8, 2013, Have you considered for yourself what impact, if any, the revelation of the existence of three errors in the system might have had on the criminal trials that the Post Office had sometimes successfully organized over the previous decade?

No, I did not do it. I wasn't aware of that, I mean, I knew we had obviously, I knew we had a um, a security investigation team, um, and I knew we were going to file the prosecutions ourselves. I was always fine, I didn't always know it, but that became I knew it from the beginning, but I had nothing left but to make sure that everything that was done, you know, there was a proper process for the prosecutions, that it was done. carried out according to the um code, the pro code for the prosecution of prosecutors, um, I had no idea.

In that, so I didn't make any connection between those errors and the previous convictions whose responsibility it was to make a connection between the errors and the prosecutions. That would be the legal team and who within the legal team, um, isn't really me. I mean in terms of my contact with the legal department it was mainly Rod rodri Williams um and I had very little contact with Janelle um and then Andrew Parsons from um wbd or Bon Dickerson or wherever they were at the time so just to be clear about the publication of the site's second report mentioning the three errors you are not aware of, no investigation or introverted look on the part of the post office as to when we found out about these errors and what we did regarding them.

I don't think he was at the time. I saw things through the disclosure that we were looking at past cases, but I wasn't involved in that. Tell us in paragraph 30 of your testimony, we already read it, you were aware before. July 13 general rumors of complaints and that had been throughout his time at the post office not since Horizon was introduced around the year 2000 no so it was really around 2010 at that time so I think it was Really , when I took over the contracts team, um and I think at that time or thereabouts there were the Inside Out programmes, there were a couple of television programmes, one in the South and one in the Midlands, I think then the Rumblings. what you're talking about, as you call them, is from about 2010 onwards, yes, I mean, there were some postmasters who said it must be the system, but it's not like I could have identified it at the time.

What are you talking about? No, you couldn't, what couldn't you point out? I can't remember where I paid attention to, in terms of there are some issues, um, it was really around 2010, 2011, where I started to really get involved, let's take a look, um. So can we start by looking at survey 0017 8171? If we can look at the bottom of the page, please, this is 2004 and remind us that in 2004 your work would have been like this. I was area head of the rural network in Wales. the rural agency in Wales, yes, and there is an email from Jill Cample, John U, the contract support center manager, under the bottom eglon and it says I passed the file you sent to Richard A Ashcroft in contract management problems for one of your team. to view and request information on Fujitsu services.

I think a telling point in this case is that no, there are no helpline calls recorded. I would have thought that if he, I think he is a subpostmaster, he believed that he had a problem. he would have done it pretty quickly, it's a little surprising that the accountant a couple doors away knows enough about Horizon to put his name in the statement, but it's a system problem; However, while I believe there is no evidence to support problems with the system, I don't think so. I want to make general assumptions and would prefer to be sure when circumstances may lead to termination of the contract.

U Richard or someone from his team will contact him in due course and then at the top of the page Mr Ashcroft will email you and tell you that he agrees with Jill. He got a member of his team to find out about this and asked him to put together a checklist of the obvious things that have caused this discrepancy at the Branch. If we can rule them out, it gives us a higher level of confidence that it really is a postmaster error and, um, he asks you. if you have any time scale on this, firstly why was this raised with you in such a low Egleton even though that's not in Wales, it was Wales and the marches, so that would have come into the area of the one I was responsible for?

This is a sub postmaster, um, raising a Horizon system error issue as a possible cause of a discrepancy and apparently he had implemented an accountant's view to support his opinion, yeah, so I had forgotten about this until I had it in the disclosure. um I do remember him with Steve Morgan um and this brought it back to me. I don't remember them not disclosing his initial request to me, um, if he came in writing, um, but back then he would have had someone working overnear. with the branches and I was supervising, does this fall into the category of a rumbling pit?

I mean, this was back in 2004. Mr. Morgan obviously expressed his concerns and I didn't know where to go with those concerns and then I arrived. I knew because I didn't know Jill Cample John at the time, um, and that was me trying to do it, so she brought up that she wanted system information, um, and then I reached out to see where you can find out where we can get that information. for him and I provided it to him, so would it be an early rumor? Yes, and do you know what was done as a result?

So obviously I sent him a letter that I saw in the disclosure, um. I have provided him with the Horizon logs, as he requested, and no, I don't remember. I mean, I asked him to compensate for the loss unless he could establish something within that, but from the information he had. From this team there was nothing in those records that pointed to the Horizon system, but I don't remember what happened after that, let's look at survey 1 42481. Is this the letter you wrote to Mr. Morgan? That's the one I've seen yes um from March 1, 2004 saying that you have been provided with a copy of the transaction log and an event log to allow you to further analyze the cause of the 400 p discrepancy.

I initiated further analysis of these records which reaffirmed that there is no evidence of a discrepancy created on the horizon. The Horizon system will not create a discrepancy only if the user corrects a mistake he previously made in this specific case and reverses an incorrect remittance of checks, as long as the declared cash figure is correct at the time. The check figure held in stock is correct and the shipping check figure is correct compared to the physical checks sent to the data center, all of which appear to be in order. My letter above gave you until a date to compensate for the loss or provide supporting evidence.

This discrepancy was generated by a system error and not by user error, please provide the evidence or recover the loss. Yes, when you were asked to participate in this, did you want to understand what the root cause of the discrepancy was? I then wanted to provide the information that Mr. Morgan had requested so that he could understand what G had in his branch. That's something slightly different. What I'm asking is if you wanted to try to understand the root cause, so in 2004 there was no facility to um investigate branch issues like the ones we introduced uh into the scheme was very much that the postmaster was obliged to um present evidence to dispute the loss he had suffered at his branch How would a postmaster present evidence to dispute the loss? in relation to a computer system that he didn't have access to, so he did have access to the computer system, it would have been for 42 days in those days, um and then he reached out to me to be able to get more information for him, which is what I have done, so at this point I have helped as much as I could.

I say I met with Mr. Morgan, so I don't know if I have. nothing more because I can't see anything. I haven't revealed anything else and I don't really remember, but I do remember going to his branch and meeting with him, so you asked Fujitsu to produce records for the case. Yes, so I asked him. our team um CU Jill Cample John is not Fujitsu and then they contacted Fujitsu so when I did some I said I didn't know where to go with this when I asked some questions about where to go. get the information they directed me to Jill cample johon um and her team I assumed they were with that link at the time Point in fij Jitsu Do you agree to know what you know now that it is not possible to identify system errors from the logs that were produced alone?

I think if there was something in the logs that you know he lost a transaction or something, but I think you know from a postmaster's perspective, they wouldn't have known what to look for and in 2004 I wouldn't have known what to look for. because I was about to ask if you were qualified to look at the records, no, so who was it, so it was team Jill and I'm sorry, I think it was Richard again, who I don't know that person, that was the team I was looking for . I asked them for the expertise to be able to provide this information to Mr.

Morgan and when I referred to you, I began a deeper analysis, was it from them that that information came from and how were they qualified to analyze the information? records to identify whether a system error caused the discrepancy. I don't know, I don't even know if they were, but they were qualified. I don't know if they were or not, but that was the point of contact. They directed me to the business, okay, I'll move on. Can we please look at survey 1 78219? um we're still in March, 2020, 2014, we'll see in a moment, can we look at pages three to four please, and um, yeah. we look at the foot of three thank you there is an email for you we can see at the bottom if we scroll to the bottom by Clive Burton from the sub post above master accounts team agents debt three in Chesterfield just help us , what they were a team was within the pnba team in Chesterfield and do you know what the agent debt was that they did not have at that time?

I mean, I've had it since then, because okay, let's see what Mr. Burton says, Mrs. Pew, this is the angst sub poost at the chid cherbury post office uh from April 21, 99 to 3 September 2001, when his service contract was suspended, the final audit resulted in a deficiency of £9,000 odd, but many error notices came later. An issue was issued that increased the total debt to 31,000 uh. Recovery was referred to Jim Cruz of Legal Services to continue the case management conference which was heard on January 8, 2004 and some instructions were given. Our Legal Services Department asked us to pray several times.

Statements about various accounting errors that are part of the debt. We are in the process of preparing them. There are a number of other matters on which our Legal Debt Department requires clarification and statements are needed. We would be very grateful if you could provide us with any help. with the following elements or saying who to contact, the defense alleges that the introduction of the Horizon system itself caused problems and evidence is needed about the training provided to Ms. Pew and, if possible, evidence from call logs to prove if Ms. Pew was seeking help in relation to the operation of the system um telephone link was cut between February and June 01 um and a statement about the closure of the office and then on the page uh General statements about how the system works are required of accounting um in a sub post office and how documents are created, so going back to the previous page at the bottom of point one, the defense alleges that Horizon itself caused problems.

Yes, this would be among the Rumors category of my memory. Yes. Because when this and again I did it. I don't remember this, but when I requested further disclosure to see what I did with this and I came to the conclusion that this to me at the time was just a routine information request, so I sent it to the contracts manager that I was. part of my team, so if we get to page three, please email us. Could you deal with them? Yeah, so Emilyn Emn, who was a contracts manager and was working with my team at the time, and he was more familiar with where to get information, what he's done, has reached out to several places and I think we can see more up the chain that on March 23 and then April 8 they seem to have received. a list of mbsc call logs relating to Cherbury between 2000 and 2004, yes, if you look at the middle of page one, the middle of page one, yes, if we scroll down, there are the call logs between those two dates from this office.

Yes, so this was the provision of information that I went to. They copied me on some and not all. I think we can see what Mr. Hughes did in survey 1 7825 at the top of the page so we can see the email from him. Linol, you try, you say you spoke to Glen about the topic below and, in particular, regarding Horizon's question, he suggested that he put me in touch with you. He mentioned that he supported several offices within the old group, so if possible he went to Cherur and provided assistance to Mrs. In the early days, then you are asking a question: did anyone go to the old Chester group to provide assistance regarding Whether or not you went to that branch?

That's what I can see in that email, yes. I know what happened after this in relation to this subpoost mistress, Mrs Pew, who had raised her defense in the County Court litigation. Horizon being the problem due to a system failure. I don't know what happened after this. It's not the kind of issue that should have triggered any investigation, a full and thorough investigation, so the investigation would have been done by the investigation team at this point, so anything in a criminal case was the security investigation team. which would have made this not a criminal case, this is a civil recovery, sorry, I am seeking to recover £31,000 from Ms Pew.

I don't know, I mean this was my first one, so this was it for me. it was a routine request because in 2001 we went from a regionalized structure to the area head structure um, no, I don't know what date, I think it was probably around this date and then all the BRs, all the branch files They were distributed to the area manager and then they were looking for information, the information they needed was not within my team, that is why I asked um Emin to facilitate the provision of information, so I do not know what or if any investigation was carried out at Regarding that time, do you think some type of investigation should have been carried out?

If in the legal proceedings the owner of the subpoost says that the loss you are trying to recover from me, £31,000, was in fact caused by the Horizon system this dates back to 2004 yes it should have been done do you think it should have been a independent investigation? That is, independent of the post office. Well, I'm not sure if it's independent of the post office, but there should have been an investigation within the post office, um, but from my work knowledge and memory, there certainly wasn't a function that did that back then and it was only when we started working on the second site and I started putting that team together.

Um, from my perspective, we put together the knowledge and the know-how to be able to handle these types of requests in terms of what you know, what has happened and we can understand. what is the cause of the loss, but I don't think it would have been done back then, but why not, my question is we have seen a couple of examples now that concern you in the roles that you play. was made relatively early in Horizon's life with the subpostmasters raising the suggestion that the loss attributed to them is in fact caused by Horizon. Why wasn't something done to investigate?

I think it would have depended on the particular area it was in. was at the time, so this would have been Chester at the time she got into trouble, so I would have expected Chester's group to have done something with it, but there was no formal approach, there was nothing documented there. There was no policy about it, it was very much, you know, it's up to the postmaster to prove that they're not responsible for the loss, that's how it was and why it was that way, who decided it should be that way? because that's what was in the contract that's what the contract was um what are you thinking about in particular in the contract?

So I think when I got in, so I started, I can go down, by the way, sorry, when I started in the the directly managed or crown network, so I got in that route and then when I got out of the branch structure and I started working with subus Masters, there were many things that were not documented, there were no policies. there were no approaches and then there were changes to the structures, um and I think it depended a lot on the people within those areas in terms of the level of support that was given to the postmasters at that time, so you know, when I left from that he managed directly and came into my postmasters area, then I was able to help in some, in some, some cases, because I had the knowledge of Horizon in terms of Prov providing the information and I had to go where I was told. get the information, but my opinion is that there should have been a feature to do that back then and there was nothing in the contract you believed that required the subpostmaster to prove that the loss was caused by the system and not him. or she said a moment ago not because of the wording of the contract, yes, so there is nothing in the contract that mentions the system.

I mean, the contract had been in place for some time before the Horizon system was introduced. you know that the contract only required the sub-post Masters to compensate for losses if it was due to their mistake or negligence. Yeah, I mean, so why do they have to prove anything? Why doesn't the post office have to prove that the loss was Will? through the error or negligence of thesubpoost Master, so I think back then the assumption was that if there was a loss in the branch, um, it was the postmaster's responsibility, why was there an assumption because it was supposed to be user error?

I'm sorry because it was assumed that I was a user why are there a lot of assumptions no I absolutely agree there were but why does a multi-million dollar company make assumptions when they have a written contract that prescribes the circumstances in which a sub The administrator of Post office is responsible so looking back there was no provision for the Horizon system, there was no change to working practices, as I said when I found out about Mr Morgan at Low Egleton there was no process to go fetch information. I had to find a contact to do that, so there were no changes in terms of policy, process or work practices that he was aware of at the time.

With all due respect, Miss Brandon Bogar doesn't really answer the question. Didn't anyone read the contract? and I think keeping this contract says that we can only recover money from the subpostmasters in these limited circumstances, the subpostmasters don't have to prove anything, that was the advice we were getting from the legal department at the time, who illegal of our legal department would well support it. so it would have been Roy Maale, yeah, who at Royal Mail, um, no, I didn't get involved in the early days, um, but I think when I started getting involved, it was around 2011, which is when we had the sh um. the Sho Smith case and it would have been um and I didn't know that I had never actually met any of them, but it would have been those on the copy list, it would have been Mandy Tolber, I think Rebecca Mantle, um, probably Rob Wilson, I think. but these are people I had no routine contact with at all.

Was it the case that you very well knew that the contract did not entitle the post office to recover money from the sub postmasters in any or all circumstances, but that is what the post office pretended to say: we have seen in the inquiry Miss Mandon Boach many letters to sub postmasters simply saying that you are responsible for making up for any loss completely ignoring the terms of the contract so if I go back to um there was Network and that's where I was and it was the management of um, the letters and the defaults, the contract was managed within Network, so it changed over time, um, but it was mainly the contract administrators, but it was always under the direction and instruction of the team. legal, so there was a very close working relationship between the contract administrators and that legal team around what they should and shouldn't do.

You mentioned what happened or what changed in 2011 when Sho Smith's claims, yes, were threatened. Can we please turn to survey 029 4879, this is an information document or a proposed response to the challenges related to the Horizon system, it is from Mr Isay, we can see that it is dated 12 October 2011 and is addressed to you, yes, and to others, and copied to others. We can see that the heading is jfsa and Shu Smith um legal access, which was essentially part of Shu Smith's response to the challenges related to the proposed Horizon system. Steering group and purpose where you, um, I think at this time you were in a very senior position as a boss. of the network um, I was quite senior, not very senior, but quite senior, so I reported to SE Huggins at this point, who reported to Kevin Giland um, so they were two levels below, um below the exact director.

We can see that what Mr. ism is proposing is to define and manage a coordinated response plan that defends existing challenges and deters future challenges in the most pragmatic and efficient way. Do you know why that was the proposed strategy to deter future challenges? Don't know. Actually, as I said earlier, I was the one who came into this fairly new space, um, and I think the only reason I was in this was because my involvement was the search case, um, which is, and my move to the um. role that took responsibility for contracts, but do you know why a company wouldn't aim to examine on its merits any challenges its agents may present?

Well, I should have. I mean, this is a very biased view. um from Rod when he put this together and just um looking further up the mailing list, do you know if any of those people, many of whom we know, said to wait for Rod? This is a biased view, so the older people here um Mike Young, exact director Kevin Gilland, sorry, the format is gone. I can't really read it, obviously, yeah, so Mike Young, coo, yeah, Susan, general counsel chief legal and compliance officer, as she knew, knew her, so another one, Chris Day, chief financial officer.

Su, I think he was my line manager at the time, John Scott was very senior so these are all very senior people here and I don't remember anyone questioning anything here but they may have, I don't know. I said this was me, did you challenge him? I didn't, this was me coming into this as a new person in this Arena, that purpose, that strategy that is laid out there, that was the strategy that the post office largely maintained until you left. It's not like that, I don't know, I don't agree, I think, and you know, what I especially tried to do was try to get under the skin of what had happened in the branches and investigate those cases, so, then, I I would.

I'm not saying I was in this space at the beginning anyway, I didn't question it because I said I came into this new thing, but when I came out I was clearly in a different space, let's see what Mr. Isme said in the background throughout the whole thing. Over the last 10 years, the Horizon system has been the subject of a series of unfounded criticisms in the national press. Reading this at the time, would you have known what that suggestion was based on? No, I mean, the criticism was unfounded. Sorry B, the criticism was unfounded. I think this goes back to my previous comment about Rumblings.

You know, I was aware of some things, very few. Certainly, I was the one who went more into a national view of this because everything prior to this has been very contained within my area of ​​work. as opposed to because there was nothing on a corporate level at the time, so I was the one who first saw this on a national level for the first time. I believe I also faced questions in the Houses of Parliament and accusations in court from former deputy postmasters and their legal defense teams the post office has consistently won its prosecutions and presiding judges have made statements that were expected to deter new unfounded allegations, however, challenges continue to be raised did you know whether the statement that the post office has consistently won its prosecutions was true or false.

I wouldn't have understood it at the time. Would he have simply accepted that on the face of it, the Post Office had consistently won its prosecutions? I would have taken it literally. Yes, I knew it? Any presiding judge who had made statements that were expected to deter unfounded accusations, but despite the judges' work, the challenges continue, not that I remember again, would he have taken what Mr. Isme said as true in this moment? What I mean is that yes, situations have arisen in a minority of cases where the post office has fired the deputy postmaster for financial irregularities and the deputy postmaster has claimed that it was the accounting records that were wrong due to problems from IT instead of the money had been stolen uh Sho Smiths are acting on behalf of a number of former sub postmasters who have met at the jfsa um the post office has received commonly worded letters before the action these are precursors to damage claims and damages request important materials the post office had about 20 cases they wanted to take to court where the defense blamed Harizon, you know what?

That's a reference to cases the post office wanted to take to court. No, I would not have knowledge of the cases at that time. The post office is confident. that Horizon is not at maximum, do you know on what basis that statement was made? The confidence that Horizon was not at fault, nothing more and nothing less than that was the understanding within the business that you refer to in your statement that the message coming from the business, the messages from the post office, yes, which person , what individual person was sending you that message, there was no individual person.

I remember when Horizon was installed and implemented that the message was this is the safest, the biggest. and the most secure system in Europe and I and I don't know who said that but I always remembered that um and and that in itself gave me confidence uh in that system but I can't, I can't say that I ever remember a particular person um, but that was the general message or the and certainly the sentiment of what was believed within the organization, so you can't identify him as an individual, no and it would have been for several years, it wouldn't have been like that, you know. only one person was that was the understanding uh genuine understanding within the organization at the time that I was aware of I mean there are parts of the organization that I wasn't aware of that I've since seen quite a bit of damaging documents, but I wasn't aware of that, what do you mean?

Well just the comments on you know the receipts and they don't match that kind of um we need to keep this quiet we don't want Horizon Integrity um to make ourselves known those are the things I'm referring to Ian when I ask questions to those people at those levels, they say that it was the people above us who told us that Horizon is the largest non-defense system in Europe, it is very secure and processes x million transactions a day and a billion transactions per day. anus. There is no FS with Horizon. has been independently evaluated. The auditors have given him a clean bill of health.

It was the people who are above us, you are people of your level, who were transmitting that message to us. Well, I wasn't at my level back then because I wasn't at that level. level um, but um, just looking at, I mean, if you look at the mailing list here, I was one of the more Junior people on this list and like I said, I just started getting into this, um and so, I would not do it. I have challenged him and I would have taken everything at face value at this point because I was new to this space.

I believe you were responsible for communicating messages from the post offices to the ministers or members of the peer. No, no, he did not attend the meetings with MPS. I would have, but not at this time, so in terms of the meetings, I'm sorry in terms of the meeting that I attended with Min um MPS, it was as we were, it was 2012, as we were getting into that, in that , the second site. investigations um and obviously we have documents that refer to those prior to this. I would have been working in a regionalized role. I could have had some local meetings with MPS um, but it would have been a norm, another normal type of business.

I don't remember that exactly, but it was in 2012 that I really started to get involved in this. You met, I believe, with MPS twice, on May 10, 2012 and June 18, 2012, that is correct and that was before the second one. site um interim report obviously a year earlier, it was before the second site had actually been committed and uh can we see um uh, the second of those meetings that you attended, I think six MPS, including James Arnot, um looking at JB 61? Can you see the list of attendees? Yes, scroll down a little bit, we can see that it includes you and this is the minute of the June 18 meeting.

Can we please look at the bottom of page one, Alice. Perkins, then the president of the company, provided background information and perspective of the post office, um, it's a completely separate entity, he realized the problem when he joined in August 2011, it was very serious, the post office recognized very well that the matter was very Serious for the masters and mistresses of subst in the second paragraph of the page, um he said that the matter that involved a strict RPP regarding money matters, the post office and its staff are administrators of large amounts of cash, the cash does not belong in the post office.

In transit, when you go through the post office, there's the issue of trying not to put temptation in people's paths and then, uh, Miss Ven. She begins by saying that temptation is a problem, but that trust in the Post Office as a brand is absolutely paramount. Were you involved in briefing Miss Um Venos or Miss Perkins for this meeting, not in relation to the narrative you're seeing here? So what they asked me to do for the May meeting was they would present two cases that they wanted. me to be able to gather the information to be able to speak through um at the first meeting and those two cases was um, it was the case of Joe Hamilton Tracy Meritt and and because they were his constituents for both MPS, that was what they asked me to do. and then that flowed, the June meeting was a continuation of the May meeting with an expanded audience, sothat my involvement was not in gathering briefing information apart from my specific place on the agenda as If you were part of any discussion with either or both of Miss Perkins or Miss Venel beforehand in which it was decided what should be mentioned is the temptation that subpostmasters face, no, we should try to drip a little poison into the MP's ears drip a little poison into the MP's ears for nothing I wasn't I wasn't part of that conversation Was there a deliberate strategy to put that idea in the MP's mind right at the beginning of the meeting focusing on the Temptation he faced? by sub postmasters No, I don't think there was, but I can't comment.

I mean, if I go back to the May meeting, I wasn't at the entire meeting with cmps, so the format or order of execution was that, Alice, it was Alice and Paula and I'm not sure if Alwin actually met with James, but as it was then and Oliver Lewin, both MPS, the agenda had several people there, I was one of them and I. I had a space, so we were basically waiting outside the meeting room or in the Café area of ​​the building, I think, and they called us to make our space, so I wasn't part of the um, the Preamble, for that soon, miss vels. continued uh of the 11,800 employees only a small number present cases where there is a problem of alleged fraud, the problem is therefore relatively small, sorry, it is relatively very small uh The Horizon system is very secure, every keystroke key used by anyone using the system is recorded and can be audited.

Did you know that was the case? Not first hand. No, did you believe what she said? Every keystroke I made used by anyone using the system is logged and auditable. I thought that was my CEO. I had no reason not to believe him. Do you know who informed him? Don't know. What would normally happen is that the information would come from the relevant Department. I would have expected her to come from our IT function and that would have been it. I think Leslie was the Boss. CIO at the time, would you expect it to come from Leslie Su, the CIO, that would be my expectation, but I don't know if that happened?

Can we continue with the meeting please to page three, one of the M PS: Andrew Bridgen at the top of the page asked if there had been any cases where the discrepancy was the fault of the system and you see three passages from the footer of the page displayed there. Paul Avenel said that going back to Andrew Brion's question: no case had been investigated where the Horizon system had been found to be at fault. Did you know if that was true or false? I didn't know it at all. I thought it was true because that's what she said, but I didn't know that in any way, do you know who informed her?

If you were told to say that, to say I don't know, I mean, if it depends on what you're referring to as a case, if you're talking about a criminal case, then. I would have expected that report to come from someone in the legal department, but it's not specific and I really don't know. I'd be speculating, can we go back to page two on that, please, at the end of there? We stand by what Miss Venel said there. All cases brought to trial involving the Horizon system so far have ruled in favor of the post office.

Did you know if that was true or false? I didn't know it at all. Believe it because her CEO was saying yes, do you know who brought her? If someone said that again, I don't know who, but I would have expected that to come from the legal team given that he was specifically talking about prosecution. I think it continues. You wouldn't have known at this time in June 2012 that at least three subpoost Masters had been acquitted. I wouldn't have known. Did you know about the case of Nicolar Arch accused of stealing £32,000 and unanimously? acquitted by a jury at Bristol Crown Court, that is not a name I am familiar with, having said that the system was to blame for the alleged shortfall and that she had repeatedly reported the matter to the helpline but had not reached nowhere with them.

If you were not aware of that case, were you aware of the case of Susan Palmer, who had been acquitted by a jury at South End Crown Court in January 2007 and had said in her defense that the Horizon system was responsible for the loss and at the same time it prevented him from challenging any Horizon figure that he had not agreed with no and again it is not a name I know did you know that in 2006 in Northern Ireland a lady called Mory mckelvie was acquitted by a jury no and that in the course of her trial had come to light uh that an area manager um her area manager had experienced problems with the balance of Horizon um on her terminal when she had come to examine the system she was not aware of that at all who would it be responsible for um putting it neutrally fact checking the type of information that miss venel is telling to a collection of MPS here every case involving Horizon that has been brought to the prosecution has ruled in favor of the post office when that is simply false Who would be responsible for gathering information that would allow a CEO to say say something like this I'm not sure if there was a person with overall responsibility my experience of how the business worked was that there might be someone holding the pen over the report but then would contact the relevant directors um uh or um, heads of those particular areas to get the appropriate response, so seeing this, I would have expected this to go to the legal team, um, put it another way, Miss Vander Bogard, Would you expect careful and diligent checks to have been carried out before proceeding? the front foot absolutely because that's what goes with the front foot, right?

It's looking down at the MPS and it says Move Along MPS there's nothing to see here that's what that line says, right? I say that in all cases it's a pretty strong opening statement, so I agree that it's the kind of information where she uses the judicial system as support. It's almost not just us who bring the cases, it's the juries and the judicial system that find them guilty. He assured MPS that there is nothing to see here, which I cannot disagree with, that it is consistent with Mr. Ism's plan also for 2011, does it not end strongly in the hope of deterring further challenges in terms of its purpose ?

Yes, I agree that you can. It does not help us establish the steps that were taken to confirm the veracity of the information given to MPs here. I wasn't involved so I don't know where the information comes from. Actually, you shouldn't hold the pen. Come on, thank you sir. I wonder if we could take a break there. I think it's between 52 and 3:00. I wonder if we could take a break until 10. Q. Yes, indeed, thank you sir. Yes, I can thank you, thank you very much. Miss vbo, can we see the meeting briefing we were talking about on June 18, 2012 by looking at survey 30272?

Was it common? I think it looks familiar to you. With this document, was it common for an information package like this to be prepared for any important meeting, particularly with MPS? Yeah, it was um, this is, um, I think um, 30 odd, uh, 33 odd pages, um, long, you can see there's an index. um up front if we go to page two um the list of attendees is established and then a proposed agenda is established with the post office leader or the MPS identified and the minutes that will be allocated um to their speaking part and as you said that you were already scheduled to deal with two cases, that is correct and if we turn the page to the third page please, we can see that Mr.

Arns was going to give an introduction and then, as in fact happened, Ms. Perkins was. to speak and I would understand that these are the key messages titled there, it is essentially a speaking note, yes, and if we can look at that page please, in addition to looking at JB 61, thank you, so we can see that the general presentations were in de fact, it was given by Mr Alnot and then Alice Perkins spoke and you can see that to some extent she follows the briefing or speech note, you can see the second point on the right, take this issue very seriously, his second paragraph of the uh very serious minute for the post office um mention of reputation which equates to the second point yes, and then you can see his last line of the very serious minute for the subpostmasters and mistresses involved, as it was invariably in the life. -change is equivalent to the second point, um, this affects people's lives, yes, yes, and then check the page on the left side, please, a huge change in the post office. there's the right public money at stake and then there's the line, there's the issue of trying not to put Temptation in people's paths, that doesn't seem to be something she was quick to say, wasn't that included in the initial briefing package? there was another version of this briefing package, not that I'm one, this is the latest version of the one they've given us, that's what I believe, yeah, and just help us with this stuff when you're in a meeting like this, also After the formal briefing, there is a kind of pre-meeting in which people exchange ideas and propose additional lines. um, there might be on occasion, um, if there was on this one, I wouldn't be there. involved in it, but as always, these are either short impacts or not meant to be scripts, they should be.

You know, this is what we'd like you to think it should cover. Thank you. I'm just looking like it's. to examine the three things that I have highlighted in the meeting the temptation that Miss Venel and Miss Perkins spoke with the line um every case brought to trial involving Horizon has ruled in favor of the post office and the line um never There has been a case investigated in which Horizon has been found to be at fault and just to see if any of those three big statements appear in any of the briefing notes that were distributed before the meeting, so if we go to what the lady says venel, if we turn the page on the right side, please confirm the previous mail administrators, a key for our business support, our branches, we have a help desk.

Horizon is used in branches to manage accounting underwriting. If you have any questions or concerns, you are confident in the integrity of the horizon built on sound principles of reliability and integrity, it has undergone many external audits and issues of this nature have never been raised at a technical level, then the three points we occasionally receive incidents of fraud this is unfortunate as public money is at stake, it is important that we protect it, even in cases of fraud we treat the agent with care and respect, so the line about each case brought to trial involving the Horizon system has The ruling in favor of the post office was not part of your report either, was it?

And then if we go to page three on the left side, please, the line in the middle of the page. Paul Avenel said going back to Andrew Brion's question. There has not been a case investigated where Horizon has been found to have a fault that does not appear to be part of her breathing, nor is it in the other document now, so I will ask again if you remember if something was done outside of the preparation of this 33 page information packet to Miss Perkins and Miss Venel to give them information to display at the meeting, not that I know or can remember, um Paula and Alice could have decided to meet themselves, sorry, I repeat, I said Paula . and Alice could have decided to meet themselves if they wanted to talk about what they were going to cover, but I don't remember, I don't remember being in another meeting, because usually you know.

You would have a warm-up meeting and then go into the actual meeting. I'm sorry. No. I'm just trying to examine where these three big claims come from. It's about Temptation. We have never lost a case. Horizon. It has never been found to be at fault, where, where did they come from, I can't see from the information that they have come out of this, I mean, it seems like you were at the meeting, did you think it was on hold? Oh my goodness, um uh, Paula Venel is no longer on the reservation here, so for this meeting, which is different from the May meeting, I was at the entire meeting, so it wasn't like I just walked into the space in the one that really was. this whole meeting, um, in my experience, it's not unusual, you know, there must be a brief package of imps or a note that the person it was addressed to could change it, um, without informing the rest of the attendees, like In the For the rest of us, it's not unheard of, so, freestyle, well, I wouldn't say freestyle, but was it adding its own potential emphasis or are these not points of emphasis, are they in terms of big claims, no? ?

Well, I say that in terms of how they would normally approach. I'm not saying that in this case, I'm just saying in general, let's look at this case. You couldn't really say that these are points of emphasis, could you? They've chosen to focus attention on certain aspects of the briefing package and bring it more to the four, is what I would say, but none of these are in the briefing package, no, there are touches on some of them, um, General theme, but come back on the left side, please on page two. All cases brought tolawsuits involving his rizon have so far ruled in favor of the post office.

Where is what is mentioned in the information package, apart from the reference to occasional incidents of fraud? that is a completely different point, it is about the incidence of fraud, what miss venel is recorded as saying is that when cases go to court we always win, sorry, I was only involved in the information package in the that I was involved and I don't remember anything in between to get to the final version, so I think I'd just be speculating, but no, I don't remember any further conversations to say that we're actually going to scale this up or down, that's what I'm asking a lot before Miss Venel and Miss Perkins came to testify to us.

Was there an occasion, that you know of, where the information that we see, we tell you about Temptation, we tell you about Horizon always winning the court seat? The office always wins in court, let's tell you that when any Horizon case has been examined, she has never been found guilty, so I remember this meeting. I remember the May meeting. I remember the preparation meetings. I don't remember anything else between them. and going back to what we've said about the three things, the part about temptation is the one I would have said something about. I mean, I wouldn't have been aware of the other information, why would you have said anything?

As I said before, my view, and my very strong view, is that the postmasters were very honest, hard-working, decent people, they did not come to defraud the business. There were occasional situations where, as I would say, situations got better. from the postmaster and I have, you know, live examples of that from my own experience um and I would have said I would have said at that moment well, look, just remember that these are very rare occasions um the other two I wouldn't have been able to. comment but and that's why I say I don't remember a conversation between those two things and finally you were in the meeting when Miss Venel said these things.

Every case brought to court we win, yes. and Horizon, when she was examined and investigated, was never found to be at fault. Did those things stand out to you during the course of the meeting? Retaining the CEO has gone off the rails here, no, really, I mean, I would have taken it because she has, uh, a has broader knowledge than I have and she has information that I don't have and that wouldn't be unusual given my role. I mean, if you think my role here was to talk to two cases, then right? I wouldn't have seen that as anything unusual.

Can we remove both? Please, thank you and refer to the initial investigation of the second site. I'm going to move forward and not examine the process by which the second site carried out its. initial examinations and investigations or the provision of information by the post office, but instead look at the response to the site's first second report. Okay, can we please look at survey 01159 one9? This is the briefing note for Miss Venel again. Yes. Remember in Preparing for the Second Site Report? Yes, to what extent were you involved in the formulation of this report? I don't really remember, other than I'm trying to think of the timeline, so, when I was with the project spy and Belinda as the direct director of the project. the program director for the project, then she and her team would normally have had the pen um, but in terms of the aspects that I was involved in, I would have contributed it, so it would have been a collective, usually a collective approach to enter. the content of such a report, but actually I can't remember exactly this one, if we look at page seven, please, a passage that we haven't seen before, so it's the footer of page six, in fact, can we see the header of advancement strategy yeah and then if we go to the next page, page seven, um, those four paragraphs, um, to what extent were you involved in the formulation of this advancement strategy, so were you aware that you were involved in conversations in terms of whether I was a driving force? in the strategy for this no, I don't think I was the driving force in the strategy.

I'm trying to remember, so if we look at it in terms of meeting James Abas, I don't think that would have happened. been Alice Paula possibly um mark of the communications team Mark Davis possibly um but definitely in terms of the 38 you talk a little please sorry definitely in terms of the 38 in terms of the communications strategy um I don't know, I think you know, early, early, my memory of the early days of um, the conversations that we had, so it would have been Alice Paula Susan, um Leslie Seal would have been at the beginning as well and Simon Baker, myself, um, they would have been early conversations, but like In terms of pushing this, I really can't remember exactly whose areas of responsibility we had, so plan A was to try to persuade Mr Arnot to postpone a meeting with the second site.

Plan B was to prepare what is described. as a complete communications strategy with rebuttal and online tactics with a focus aimed at minimizing reputational impact on the post office. Yes, MH was that the strategy that was in fact adopted, rebuttal and tactics aimed at minimizing the risk of reputational impact, I think in terms of Reputational Impact, um, because at this point Second Sight felt that they were not evidencing, evidencing quite a bit of what they claimed, so he was saying that they were not proving what they claimed. Sorry, who said they weren't showing. what they were claiming, so that was in terms of looking at what they were saying they hadn't, so this is the interim report, right?

This is the interim report from July 8, so before this there were 47 cases. um that was really contributing to this and that's through the spot reviews, but when we got to the interim report, if I remember correctly, there were only four spot reviews that the second site was talking to and my recollection of that is not one. Of those four cases were actually concluded, so there was no absolute outcome and I think that was what drove, you know, and it was a collective vision. I'm not telling anyone, it was a collective vision that there is a problem.

An allegation has been raised or made that some investigative work has been done, but we have not actually concluded that, however, the interim reports at least highlighted the problems with Horizon, did they not include the two anomalies as described? Yeah, um. In fact, a third also had some consideration within the post office in case we look deeper into Horizon to see if there are any other issues with it. I don't think the first priority was damage limitation and reputation management. No, I don't think it was as Stark as that, I think protecting the brand at all costs, no, no, no, that wasn't my feeling at the time, my feeling was that this was this.

It was the precursor to the plan, um, we had done it, it was quite a lot, this was almost a pit, it had been a year since a second site had been contracted, um, we had put a lot of effort into the investigations, but we had very little result , so it was about the fact that the rebuttal would be to the extent that there are allegations of claims, but they are not substantiated with evidence because the investigations have not been concluded. I think that was the focus here, rather than just an absolute um. brand limitation that wasn't the driving force behind this let's get it out of my memory let's get rid of the independent researchers and get one of the big four involved paragraph 40 yeah why was that the plan?

I think it was because in my early memory from before we got involved in the second siege. I remember being in some of the early conversations about what we should do in terms of focus and at the time it was kind of one of the big four, um, but that was ruled out in terms of preference. with the second site and me, why the preference for the second size before they did their job? Sorry, why did we choose the second site? Yes, before they started their work, you go with them. I'm not exactly sure my opinion would be that, um, that.

It would have been less expensive than getting one of the four great falls in um, but I also think about addressing some of the other issues that were being claimed, um, that would be outside of the Horizon system itself because, as you've seen, focusing or expanding the scope Ed uh, when the second part went live and said we had to expand the scope, which is what we chose and why, after the independent reviewers produced their independent report, was it considered replacing them, from my point of view Seen, that was simply around cost and lack of production, so one of the big four would be cheaper than Henderson and Warmington.

I'm not saying cheaper, but I think we could come to a conclusion quicker than what we were looking at at the moment because this was a year later and we had very little production but we had spent a pretty considerable amount of money or it was proving to be too much. independents for the Post Office, well, that was certainly not my opinion or it was someone else's opinion. more I don't know, I mean, that certainly wasn't um, that wasn't shared with me, nobody blame Susan Kryon for suggesting them, um at the time, I didn't think about it, I mean, obviously I've been hearing things this week.

Susan, you've got these people for us, they're too independent for us, why don't we go with one of the big four? So we can't manage and control it, so that's not a conversation I was aware of. I remember in the first few conversations Susan said saying um yeah I know I know these people um and she clearly said at that point I'm not making any recommendations um I've worked with Ron um if you want me to do it I can set up a meeting and you can have your own opinion. I remember that conversation perfectly, at the beginning, so what you just said about them being too independent, that wasn't something I was a part of in terms of conversation, um, yeah. working very closely with him at the time, particularly with Ron um and yeah, it was a big challenge um and so they should be.

I mean, that's what I'd expect them to do if you were aware of a suggestion that Susan Kryon hadn't marked the second site correctly, not before. Listening to her testimony yesterday, were you aware of chatter within the business? Rumors that umSusan Kon's job was at stake because she introduced reviewers who were too independent and B, when they were introduced, had not rated them. I control them, that wasn't something I was aware of and in fact Susan Leing was quite a I'm surprised why you thought she was gone? I suspected it had to do with the fact that the second site was not delivering on time in that time period, so it was about the quality of the second site's work. about the timeliness and the quality, I mean the quantity, the amount, we weren't seeing results, so she felt embarrassed that we had introduced the second site and they weren't producing enough work fast enough to Wasn't the impression that I had of His?

Why did you think she left? Look, I mean, I heard the evidence from her this week. I wasn't aware of the conversations and what was going on in the background. I knew Susan. she had introduced a second site to the business, she hadn't recommended them, but she had introduced them and we were in that space, that was a good thing. She had seen him, you know, he had seen her package, um and they met. as very believable, so I don't think I personally ever thought she was embarrassed by anything they were doing, but she was aware that we weren't getting the results we thought we were going to get at the time, can we turn around? in the document, please to Annex One, which provides an overview of the process, so if we move forward in the document to page eight, please, and if we look at the bottom of this page, under the activity of the post office, has provided continuous information. support to the second site and responded to the 10 point reviews that you have and then the second point from the bottom Lea is closely with Fujitsu so that your Horizon experience supports each response and then lastly you collected and interrogated transaction logs where the second site has made particular reference. identifiable transactions by taking those points in turn and keeping in mind that you are, I believe, responsible for managing the provision of information to a second site.

Was it right that the Post Office had liaised closely with Fujitsu so that her experience supported every answer that was given? It wasn't me who left with Fitsu, so Sor, that wasn't me who left with Fitsu. I didn't ask if you were in contact with Fujitsu. I asked if you know if the post office is in contact with Fujitsu to back up each answer. I understood that yes, um and I think at this point it was Simon Baker who was leading that, secondly he records that the post office collated and interrogatedtransaction records where the second site had made reference to particular identifiable transactions.

Did the post office only check transaction records for spot checks? I don't think so, I think we went broader, we certainly did in the Lepon Leon case, why does this say then that the post office interrogated transaction records? I'm thinking in particular about event logs or arc data and I'm trying to remember, so in the case of Lepton, I had several conversations with Rong about that and then we got the arc information. I think it was definitely a broader conversation because we needed to get more information to understand what had happened. at Leon Branch um I I I can't remember again I think this would have been Simon uh facilitating this from Fitsu Ok, if you were aware of the extent to which Fujitsu had examined the audit data for all the spot reviews.

I can not say it. That was, do you know why that wouldn't have been done? I don't know why it wouldn't have been done because that's the approach we took to the plan and this was the precursor to the plan, so it's entirely possible that it was done, but I can't say I categorically knew that. I thought you were responsible for managing the supply of information to the second site. I did not say no. I thought I said it. No, there was no response. You were facilitating the flow of information to the second site, but it came through you.

Some of it didn't make it all, um, but it was more of a collective approach and Simon from the IT team because he was. and the change was that I think it was Simon who was in contact with Fitsu, our contact at the time, I think it was Pete Nome, who was Fitsu Faing's account manager at the post office, yes, as seems to be the case , the post office was completely convinced that its system was U robust. Would there be any reason not to interrogate all the data held by Fujitsu? Sorry, can you repeat that question?

Yes, if that appears to be the case, the post office was completely convinced of the integrity of their system, the robustness of their system. your system, would there be any reason not to investigate all the data that Fujitsu had in relation to all the spot reviews, so you would have expected the improved arq data to have been investigated? Not sure about the enhanced AR data at the time, but definitely the standard bow, um, why aren't you sure the enhanced bow would have come under scrutiny? I don't know what they would have requested, um, who, day again, it would have been Simon, I think so. was Simon Baker, uh, in terms of liaison and directly with Fujitsu, but these paragraphs here are intended to give you comfort, are they not for, Miss Venel, that Fujitsu has been closely involved and data has been obtained to support the response of the post offices to Second?

I agree how this could have been approved without a full understanding of the extent to which Fujitsu actually assisted the post office in investigating spot reviews and that that could have been the case all I'm saying is no. I was directly involved in that and I'm not sure, I can't remember that being absolutely the case, but it very well could have been thanks, that may come down, can you remember a plan to ensure that the post office took on the role of investigating the cases raised by sub postmasters in lieu of a second site not to put things under the control of the post office and then remove the second site from the entire process Ely so I've seen some information released um and from memory that certainly wasn't in my mind and apart from um, if we were to go into a business as usual situation, uh, because having established an approach and I'm talking more about the outline, um, I was very much of the opinion that we needed to incorporate that into the business as usual so that we had the support to be able to investigate issues within the branches that SEO Master raised with us, but in terms of the intermediate scheme, I mean, yes, I was involved in some of the conversations, but I never saw that as I'm not sure Had I seen it as a reality, to be honest, you were never aware of a gentle plan to take the second site out of the equation, I mean, I've, I've seen documents that say that, but that wasn't on my mind at all. , it means that it was working very closely with the second Insight um in these cases.

Can we please look at survey 381 1544? This is an email exchange that you were not a part of, it's been a couple of weeks after we were looking at a moment ago and it's an email exchange between Mr. Baker and Ms. Venel, he was leaving, yeah, yeah, and I wasn't sure about the timeline, but I can see that this is It would have been close to that, yeah, some final thoughts here, they're not at all radical and in your first indented paragraph, the main focus has to be on showing the JFSA and MPS that we can take on the role of independently investigating cases, just stopping there, can you imagine? any circumstances where the post office could ever independently investigate itself no, the sub postmasters were making accusations against the post office right? yes, the subpostmasters were making accusations against the post office system, couldn't they? yes, the post office could never investigate them independently, couldn't they?

And if you had seen this, you would think it was just absurd. Babble, so when I first saw it, I think it was this week, I was surprised by the content. He continues that way. start putting things under our control, that was always the plan, wasn't it a concern among senior leaders? It was a bad thing if the investigation of complaints was not under the control of the post office, so that was not my opinion, so when I got involved at the beginning and in the first conversations it was about genuinely getting to the truth, getting into under the skin and understand if there was any substance to the claims that the former postmasters were making at the time, so you know, this is like I said.

I found this quite, I found this quite surprising, you know, I was surprised by what I had seen here and that wasn't why I got involved voluntarily because I came into this out of my own power, it was the post office's concern is that if the things are not under our control and, on the other hand, are too independent, we cannot influence their results well. Again, from the disclosure I've seen, I can see that, but that's how it was. I'm part of those conversations, you know, I generally believed that when we got involved in the second site, it was for genuine reasons, but I think we didn't expect it to have lasted as long as it did, but I say that the cases were much more complex to investigate than I think they were. no one anticipated at the beginning.

I'm sorry. I'm probably straying a little more into outline here. The concern was that we want to control the process and then that way. we can have control over the substance of the conclusions again, that was not my opinion, the suggestion is that the plan to do this is to augment the second site with resources from the post office, increase our credibility and then at the appropriate time, delete the second site, that's what happened, isn't it okay? In terms of you referring to closing the plan again, all I can say is that I was not aware that this was the plan, um, it was the initial plan according to this, but I was not part of that conversation and so , if we look at the next paragraph, it was said that the strategy fell almost entirely on his shoulders and that was certainly not what I was aware of at this time, which is the end of August.

Did you know it was the post office? I plan to remove the second side um, I mean, I've been in a few meetings, I don't remember which ones when the concern about the rising cost of the second site was reported, not getting the results, um and there were some alternatives that were being silenced. you know, bring in some additional resource, um, but it's just through the outreach process that I've seen the extent to which some of those conversations had a concern that they were too independent for the post office. I didn't think about it, um like me.

I said it was about the level of production and cost. I didn't think it was about their independence because I was part of the task force and they clearly their role was to be independent and that's how we operate according to um. Mr. Baker, the strategy was going to fall to you, you were apparently in charge of facilitating the second site behind the scenes and then, out of the equation, were you ever told you played that role? No, I said it was a complete shock when I saw this happen. Have you ever done anything to carry out that strategy?

I don't believe it. I mean, I was there to investigate the problems of postmasters. I mean again they overlap with the initial consultation for the spot reviews and then going into the scheme my role was to lead the team to do those investigations as best we could um in the initial consultation with the spot reviews I already had a couple of people doing that um and then we build and then obviously coming into the scheme you would work very closely with Mr Baker right? No, no, before you get involved with this. No, no, I'm talking about this on the second site.

Oh, sorry, investigations, he already told us that he was responsible for the IT side of information provision. The first time I met Simon Baker was when we were having the first conversations which would have taken place in 2012, during that whole period which would have been about a year if he had left in August, so I worked very closely with him at that time, So for about a year, I worked closely with him on the second site project. Yes, do you know how he seemed to have held the view that the approach had to be to put things under the control of the post offices and then at the right time to remove the second site without having told you.

I don't want to say that Simon was having many conversations with Paula and I assume that Alice was working for Leslie SE at the time. I don't remember when Leslie left. Well, but that certainly wasn't a conversation he had with me. Eventually, the post office removed the second site. Once we complete investigations into the plan cases. Yes, are you saying that, as far as I knew, that was not related to the plan described here? worried, yes, but again, I hadn't seen this, it's a bit like the email on December 5th, it surprises you a bit, no, it's different, I mean, they sent me on December 5th.

I didn't read it, this was never sent to me. I don't think so because I've definitely never seen this and I think it's a note from a private note from Simon to Paula, um, so this is completely different. Thanks for coming. In your opinion, did the second interim site report of July 8, 2013 raise concerns about the integrity of the skyline? I think, going back to my previous comment, allegations and issues were raised without them being supported by evidence, so in that respect uh, it was not conclusive um, but it raised concerns at the time, concerns that needed to be investigated yeah, it raised the existence of three errors that had operated in the past, well, we revealed the errors to them, so in that sense it gave them I guess what he did was bring it and make it public in that um, you know? who revealed the errors to them there, Quite a few people claim credit for revealing the errors, so my understanding was that it was Simon Baker who provided the information to the second site, but I've seen other things that say that's different, but my memory of the time, that's how it was, that's how it was. that there was some credit for Paul at the post office because it was a voluntary disclosure with no pressure from the second site.

I assume that is so, so you were aware at the time that the post office had processed many, many people. in the past based on evidence from Horizon. I wouldn't say many. I was aware of some. What was your impression of how many people the post office has processed in the last 13 and a half years? I'm not sure. At that time I had had a number, um clearly, I've seen the number since, but my first memory is that I wouldn't have been aware of the number of cases nationally, they would be the ones that I would have been involved in. or even close if it were some cases, you would have been aware that the information in the second site report and the disclosure of the errors may have impacted those processing.

Like I said before, I wasn't close to conviction, you know? the process for convictions um and can you help us? What have you done so far today? You said you weren't close. Many things. No. I said the prosecutions. What I did. I was not involved in the prosecutions. I was not involved in the briefing. I wasn't involved. in it you were not involved in providing information about Horizon to the second site you were not involved in the investigation of those first complaints about Horizon that I raised you were not involved in considering the impact of the second site report on convictions what were you doing at this time?

Well, I also had a separate function,at 9:45 and if the worst happens, you will have to wait a few minutes for me, but if it arrives on time, we will be there. on time thank you very much 9:45 so thank you before I stop um uh Miss banden Bogard, it is customary for me to tell Witnesses who adjourn for the night that they should not talk about their evidence. I don't doubt you've heard that. before, yes sir and no doubt you do not want to talk about your evidence so please comply with that request. I will appreciate it, thank you sir e e e e e e e e for