Good morning sir can you see and hear us yes I can thank you thank you very much sir as um everyone knows we’re sitting today between 11:00 a.m. and 2:30 p.m. and um certainly no later than 2:30 p.m. if it suits um you sir I would

Propose that we take a half an hour’s Break um between at 12:30 and 1 p.m. so that the evidence sessions are split into two one and a half hour slots that that’s fine by me and I take it that’s okay with the um transcriber we’ll see how we go um if um

It becomes a problem then um I’m sure she will let us know yeah than so can I call um David paet please I swear I swear by almighty God that the evidence I shall give that the evidence I shall give shall be the truth shall be the truth the whole truth the

Whole truth and nothing but the truth nothing but the truth good morning Mr posnet my name is Jason beer and I ask questions on behalf of the inquiry can you please tell us your full name please uh David posnet thank you uh thank you very much for

Coming uh to give evidence to the inquiry today and for the provision um of a deta witness statement to assist us in our investigation can we start by looking at that document please I think you’ve got it in front of you at tab A1 it should be dated the 4th of October

2023 and excluding the exhibits uh index it’s 44 pages in length yes that’s correct um is that your signature on page 44 it is yes and are the contents of that witness statement true to the best of your knowledge and belief yes thank you now a copy of that’s going to

Be uploaded to the inquiry’s website I’m not going to ask you questions about every part of it just um selected elements of it and you’re to uh here today to assist us uh with the issues arising in phase four of the inquiry which is the investigation and prosecution of sub postmasters for

Criminal offenses can I start please with your um uh career I think you worked for the Post Office for 31 years is is that right that is right yes um I think you started in 87 is that right it was 1986 86 that’s right and finished in 2017 that’s correct

Yes so 86 to 2017 31 years yes and you started life um in the post office as a counter clerk is that right that’s right yeah and I think that job lasted for for 8 years until um about 95 is that right 9 years till 95 about that it’s about that

Yes and then in 1995 you started a new role as an auditor is that right that’s correct and whereabouts were you based as an auditor I was based in Guilford and did you have any um professional or other qualifications to be an auditor no I think you stayed in that role for

Um four years or so until 1999 when you took up a job as a um a joint business testing analyst is that right yeah I think it was uh the back end of 1999 yes and we’re going to come back to that in a moment because the work that you did there may

Be of um relevance to the inquiry and that lasted until 200000 is that right it lasted until the end of December 2000 yes okay so it was a few months um yeah so um a year or so no it was it was during 1999 about Midway or or a bit further

And it I finished that role at the end of December 99 oh it was just in um 1999 was it yes right okay so about six months then maybe less than that but roughly it was a few months and um in your statement you say in 2000 you started work as an

Investigation manager based in Twickenham is that right yes and as an investigation manager were you managing uh investigations or managing people uh investigations okay did you manage any people no okay uh you moved I think from Twickenham to woking and in 2004 you were promoted to an investigation team manager is that right

That’s correct and did that mean that you then started managing people as well as investigations yes and how many people were in the the team that you managed um it fluctuated but roughly between four up to eight people and did they all work in working too no they didn’t they were dispersed

Geographically and did they homework or did they have an office that um they could come into back then we had offices right and how did you um monitor or supervise these four to eight people uh did the regular onet to ones um I I usually went to their office to conduct

A onetoone might have been every month or six weeks or so um and team meetings we’d sort of have at my office so I’d generally go to them but the oneto ones but team meetings that’d come to my office and how um frequently were the team meetings where everyone in the team came

In probably every month or two and were they scheduled um we’re having a team meeting every month or two uh or were they only when the the occasion arose they were scheduled would’ have a meeting I think and at that meeting we’d penciling the date for the next

Meeting and was a sort of a standing agenda for those some bits were standing agenda uh like any new new um post office related products or transactions Etc um and also I used to print off everybody’s current cases um and that they could select a

Case or two if it was unusual and and talk about it um and it was also used for if if somebody had an investigation and needed someone to help them on the the day of um when the operation concluded you know because we were all

In the same room we could all uh sort those sort of things out when an investigation um um manager submitted a file for a decision on prosecution did that have to come through you before it got to Legal Services or to somebody else I I think it went direct to the casework

Team and then up to the criminal law team so um it it didn’t comes have to come through you I don’t think it came through me but they would email me um for example their reports maybe okay so you would see something about the cases that were

Going off to the criminal law team um investigated by members of your team yes would you um conduct reviews of their files the investigation managers I didn’t conduct reviews um but I did read obviously some of the reports and what would cause you to read the reports um because I’m their manager

Just to make sure there wasn’t any uh horrendous errors or or anything wrong so you’d have a good idea of the things that your uh Team were investigating the nature of the investigations that they were carrying out and the conclusions that they reached in their investigation

Reports yes and to whom did you report in this period I’m talking about 2004 onwards when you were the investigation team manager when I was the investigation team manager I reported initially to Manish Patel who’s a senior investigation manager um and then I think after him it was Trevor Loi

Um I think they were and then then perhaps Dave Paro after that and was there only one senior investigation manager I believe so yes I think you stayed in that role until 2007 is that right yes and in that year 2007 and then 2008 you worked as a casework manager based

In croon is that right it was yes for a number of months between 0708 yes what was the um function of the casework team in Cen the function of the casework team was it was sort of split into two on one side was banking um the post office card

Account so there was an assistant manager and some admin staff who primarily dealt with um DPA requests from law enforcement uh in relation to data protection act requests yes yeah um and then the other side was another assistant manager and admin staff who dealt with um uh investigations so as I mentioned

Earlier the the case File would come into the casew work team uh they’d complete a spreadsheet with I don’t know date of interview um or date of summons or or anything relating to the case um and then they would send that up to the criminal law

Team so what was the what did they add the casework team what was their purpose their function if you like the bits that not the banking side the investigation side on the investigation side W with the spreadsheet that we used which was I can remember was horrendous

It was um the movement of the case throughout its life cycle um and to ensure that it’s dispatched to the relevant people and emails uh sent to relevant stakeholders um so it was it like the central admin for uh a case and was it only an administrative

Function or did it perform any task masks of um of substance in relation to the investigation in relation to the investigation uh possibly um obtaining the audit uh requests from Fujitsu um anything else other than that we’re going to come back to that because because I think you’ll realize that’s

Quite a big topic for the inquiry so that function sat within the casework team in cyon obtaining audit from Fujitsu yeah um anything else I can’t think of at the moment anything else and how many people worked within the casew work team on the investigation side of the house there was two or

Three and they were managed by one assistant manager is that right that would include the that would include the assistant the assistant manager and you did you sit underneath the assistant manager I I sat above the okay and your title then was casework Manager casew work manager

Okay and at that time to whom did you report I think it was Dave Paro at that stage and was he based in the cin office he wasn’t no he’s uh up in St Helens I think he he lived and did you um have meetings with him or regular contact with him or

Because of the geographical um separation not I had contact with him um I don’t recall it being regular then I think in um later in 2008 you became a fraud risk manager is that right yes so that moved you out entirely of the casework team in coron is that right uh

Yes and that lasted until 2010 yes uh what did that job entail fraud risk manager it was primarily uh running fraud risk programs um for example fraud risk program on uh Crown office cash losses scratch cards overnight cash Holdings um post office card account rejected postage labels so

I would say 90% of it was these particular products or transactions um and we draft up um a program um to address uh risks and weaknesses in those areas and by a program do you mean a computer program or a a schedule of work a schedule of

Work um and it was the crime risk team that was based within the security admin team who identified these as more um high-risk areas then I think in 2010 you became an accredited Financial investigator is that right yes yes it took a while to get the accreditation but

Yes uh you stayed in that job until 2014 is that right yes uh I think your accreditation was given by the mpia the National Police Improvement agency is that right that’s right yes and what was your role as an accredited Financial investigator uh my role was basically um to recover losses on

Behalf of the business so this is essentially proceeds of crime work is that right yes and was that all postc conviction work a confiscation was postc conviction um pre-conviction would be things like restraint orders um and production orders and whereabouts are you based when when you were an accredited Financial

Investigator that would have been in I think old Street in London then in 2014 uh and until 2015 you worked as a security and investigation team leader is that right yes you retained your um title as an accredited Financial investigator is that right that’s right um did you do any

Financial investigation work yes but it um sloped off during that period I mean I to be honest I I did many of the roles i’ previously done in that last year as um a security and investigation team leader what was your function again it was um as I described

In 2004 manag a team of people uh but it also had a security element at that stage so the team would deal with burglaries robberies um uh cash centers security visits Etc and then finally I think um in 2015 until 2017 you were a branch standards manager Branch standards field manager

Yes and what did a branch standards field manager do the main thrust of that role was to check that uh sub post Masters or staff were having the correct conversations with customers in relation to uh items they were posting over the counter uh one of the focus was um whether items

Were prohibited or restricted um and to make sure that they were asking the right questions was there any investigation uh function within that role no can we go back then having looked at uh briefly each uh stage of your career in the uh post office to the time that

You were um involved in um 1999 and um I think your statement says into 2000 as a joint business testing analyst for um Horizon and can you help us um Ju Just again I think I missed it earlier how long you worked as a joint um business testing analyst for Horizon

4 if it was mid 99 I definitely finished on the on at the end of December that year so I would say 6 months maybe a month or two more or less and tell us what um a joint business testing analyst in relation to Horizon

Did y so that I was based within I pathway as it as it was known then um so you mean physically based yes they had offices in Felton um and they had a quite a large room called I think was called the rig and within that room were lots of computer terminals that

Reflected the names of post offices um and they they chose football teams so you’d have Liverpool Post Office which might be a a single terminal you could have Chelsea post office which might have three terminals a bigger busy office that would represent um slightly better post office

Potentially um and and my role and a colleague who joined the same time as me we would basically get scripts um and we would literally have to follow these scripts so it would say go to Liverpool Post Office log on sell a first class stamp take cash for it and

Literally just follow a basic script like that um and so a rig was it was a a dummy system is that right yes yeah was it um self-contained a closed system or did it um connect with the outside world I don’t think it connected with the outside world um and that’s

Basically what we did follow these scripts and when we’ finished we’d hand the the script over to I think it was a back office team so I don’t know whether the system communicated with them um but that’s what we did it was just literally following these

Scripts were you um aware in this time as a testing analyst of um significant problems arising with the development and uh testing of the Horizon system I can recall two things number one um the system was meant to have uh benefits payment system attached to it so to pay out pensions and that

Was pulled I think during the time I was there which is quite a significant I don’t know the reasons why but the government said we’re not going to be going down that road and the other noises for want of a better word I can remember were people said that

Horizon was chosen sorry Fujitsu or R pathway were chosen because it was the cheapest option so I don’t know which other companies tendered for the uh system but Fujitsu or Ico pathway would chose what about problems um at an operational level with the system were you aware of

In this testing phase um with issues and problems with the operation of horizon I was aware of uh issues whilst testing because that’s what you do in the test the purp yes um but but for example you know if the script said issue a motor vehicle

License that this is just an example not an actual example but you’d go to the screen and the motor vehicle license wouldn’t be there so you you’d have to annotate the script to say can’t perform this transaction because the icon’s not there that would go back to the back

Office Team and and I think they would look at it sorry um and then Rectify that issue the only problem I do remember was I think there was a a a northern isand icon um an nor Island icon yes there was a picture of somebody with a green

Sweater and it was raised that perhaps this green sweater should be made purple because of the political situation were you um aware of what happened when a problem arose in testing you wanted to issue a dvla license and the script told you to and it could the

System couldn’t and you put you handed in that script marked up in the way you said saying uh can’t do that function were you aware of the next steps or were you a sort of a smallish Cog in in a larger set of Machinery uh I was a

Smallish Cog that would be relayed back to the back Office Team and then after that I don’t know we would then get another script to work on um so you wouldn’t see what the solution was to that problem or indeed whether there was a solution to it I wouldn’t see it and

To be honest I wouldn’t understand anyway if if if if I did see it and why wouldn’t you understand if you did see it because that would be far too technical for me I think it’s right that you didn’t have any qualifications or experience in Computing no is that that’s right

Yeah were you aware at this time of um something called AIS or acceptance incidence not that I recall no do you um remember any of these testing issues um affecting uh settling accounts or balancing no is that um it’s 23 years ago now and therefore I um I can’t remember one way

Or another what each of the issues were or or I don’t think any of them involved balancing issues I again I can’t remember specific specifically 23 years ago but there may have been um I mean when I mentioned the scripts that were used if it ended up with um a cash account for

Example and before that there were problems in finding icons and things we may not finished the script because we couldn’t end up doing the cash account that would come out the way it should have done um but I can’t remember can we um just look at one

Example of maybe one of the things that you were doing when you were a joint business testing analyst by looking at fuj 302 1692 can you see this is um a document called a pinnacle can you see that I can yes do you remember Pinnacles I can the word

Pinnacle rings a bell but I I can’t remember it you can’t remember what their function was or who issued them or no what their purpose purpose was no we can see that this one was opened on the 2nd of June 1998 thank you Frankie and uh the

Summary of it to the left is epos do you remember what epos was is that electronic point of sale yes um and there was a problem it says the transaction logs were not working with epos y i take it you don’t remember that as a problem I don’t remember that as a

Problem um and that was before I had that role anyway that’s what I wanted to ask you um about if I may if we um turn to page five please and look at the bottom half of the page thank you and can you see I think

It’s five lines in now it says the ba stroke pockle reports and receipts document reflects the system it does not specify the requirement for transaction logs the requirement to offer the same functionality as the existing system sorry the requirement is to offer the same functionality as the existing

System two joint testers uh Chris Phillips and Dave pnut are currently checking the transaction log fun functionality on Horizon a against the documented functionality of the existing system B for usability which is what this Pinnacle was originally raised for so a number of questions arising from that firstly this

Um uh Pinnacle was raised in June 1998 and this entry is in September 1998 and it refers to you along with Chris Phillips as a joint tester yes do you think you were in fact doing joint testing or had the role as a joint tester earlier than you thought uh

If if those dates are correct then yes but I’m sure it was 1999 but Chris Phillips was the other guy who um joined the same time as myself I I thought it was a few months in 99 cuz I can remember the millennium bug that we everyone thought that all the computers

In the world were going to stop so I didn’t think it was 1998 I may be wrong if this is um accurate and we’ve got no reason to think um the dates on here are um are wrong it looks like in the Autumn of 98 you were performing the

Role of a joint tester yeah and it refers to you um checking the transaction log functionality on Horizon that sounds something slightly different to running um a script seeing whether a a test rig could uh perform a function like issue a dvla license would you agree that element

Does sound different yes what you understand it is saying here or it is recording you as doing checking a transaction log functionality it says that yes yes but what what do you understand it to be referring to um that we were trying to obtain transaction logs from the system within in the

Rig and what do you understand transaction logs to be um a record of all the transactions entered on the terminal over a given time frame yes thank you that can come um down please how um collaborative was the joint testing team I.E how uh much exchange of information was there between you about

Issues or problems with the system my recollection was um as I’ve outlined we followed the scripts and those scripts whether they had worked out correctly or not were passed to the back office team for review um and to rectify anything if anything needed rectifying when you left this role what

Was your view as to the reliability and integrity of the data that Horizon produced I don’t recall having uh any concerns because although it was a new role for me my understanding was that the testing environment was to test test test um identify issues and then people with more technical knowledge would

Rectify them um so I don’t think I gave it any any serious thought I thought that was part of the course for that particular role what was the um chat the um conversation um the feeling amongst those with whom you were working as to the adequacy or otherwise of the Horizon

System was it seen as problematic or difficult were people saying look um there are lot of problems with this we’ve got to roll R out coming around the corner yeah um a deadline to meet I don’t recall any conversations but I do recall that the the rig was down quite

Often so for example we’d have a script and we’d have to go and do some work but the technicians were working on the rig so be honest there were hours where we had to just get on with other things whilst waiting to go in so there were

Problems um I wouldn’t know what those problems were because we were just told when we could go in and start um following the script again so how what was your overall impression of horizon when you walked away from this job it was a new computer system um for all post

Offices we mentioned epos there I think it was also partly based on um echo which uh Crown officers had had been using for a while yes MH was there um anything in particular about epos that had um raised concerns about the operation and functionality of the EPO system not that I can recall

Now were you involved in um any way in the training of sub postmasters in the roll out of horizon no did you have any function concerning um the roll out of horizon no when I when I finished that job um at the end of 200000 uh after Christmas I then became

An investigation manager or temporarily became an investigation manager until there was interviews for the for the posts on a permanent basis again when you left would you say that um your experience was was that testing had revealed some problems no problems or significant problems with the operation of

Horizon I would personally say some to significant because I I don’t know what the norm would be in terms of errors on a computer system uh during a testing phase can you remember delays to the program of roll out due to technical problems with Horizon no all all I can recall is I

Think it was meant to be rolled out in 2000 and it was rolled out in 2000 if if there were a month or three of delays because I wasn’t in that role then I I don’t know can we just look at something that you said about this period of time years

Later in in 2015 by looking at two documents alongside each other if we may um firstly poll 306 370 and secondly poll 0011 8547 thank you we can see um that this is a um on the left hand side a post office limited submission to a bay business um

Innovation and skills or Biz um business Innovation and skills committee um inquiry into the post office mediation scheme which was conducting an investigation in 2015 that’s the document on the left hand side yeah and on the right hand side we can see in an email from you to

Helen Dickinson and Rob King saying I’ve trolled through this and made some comments yellow and blue highlights not many though uh as a lot of it is technical or not within my knowledge to comment further uh witness statement Associated to reflect Horizon training and you say as an asign in my

Personal view I really do think that there are cases where Horizon is clearly irrelevant the sub postm admits theft says what he did with the money Etc no grounds to even site Horizon George Thompson mentioned the rodkin case um at the Select Committee hearing there are others and I think without mentioning

Names details Etc we could be more on the front foot if these were flagged to MPS second site Etc so the parliament’s conducting an inquiry an investigation uh the post office has given some evidence already um through um Mr Thompson and this is a on the left hand side a

Submission um to uh that parliamentary uh committee and you’ve marked up this draft um submission and can we just look at p page five please on the left hand document and uh have a look at training at 2.1 thank you uh the post office was proposing to tell the committee that it heard

Evidence on the training available to sub poost Masters at the time of Horizon’s introduction this evidence focus on the pack of training material is provided to of postmasters at the relevant time Etc and then next paragraph As presented to the committee one might left be left with the

Impression that the training and support ended there on the contrary on the introduction of horizon two different training courses were then provided by Ico pathway the first was for sub poost Masters the second was for staff this training was delivered prior to the branch migrating to Horizon all sub

Poost Masters left the courts with a horizon user guide and they were also subsequently provided with a quick reference gu with quick reference guides and then I think the part that you added this would have been marked blue or yellow in the um original was quote it was also a past

Fail course so if they weren’t up to scratch they weren’t allowed to work with Horizon it wasn’t a case of going through the motions C Associated witness statement which may provide um more ammunition now this you were writing in 2015 yes uh yes yes we’ve seen the email the

Email yes enclosing this document with these markups on it yes yes and what um direct experience had you got of um the provision of training to sub poost Masters sorry could you repeat that yes what direct experience had you got of the provision of training to sub postmasters at the roll out

Stage um none but you’re here providing um ammunition it says or you say to those that are compiling this um submission to Parliament if you had no direct experience of the provision of training to sub postmasters why were you providing the ammunition um firstly I don’t remember or recall that

Document secondly I think when we were um investigating case is one of the things we got on occasions were the training records um and it would have been from those we were informed that it it it was a past fail course so that’s probably where I took that

From and so this addition that you’re suggesting to the submission to Parliament comes from your knowledge not from the period that I was talking about as a tester in roll out but later when you were in an investigator is that right yes and to what extent did you look into the adequacy of

Training as an investigator um I think it was if we obtained the the P well it’ have to be a pass otherwise it wouldn’t have been working in the post office um and again I can’t remember I don’t I don’t know whether it was simply a pass or whether there was

Some text um competent with this okay with that or issues with this Etc so it gave a picture of a sub postmaster or a clerk as to how well they were coping with the system during training did you invest investigate um the quality of training no did you ever hear some postmaster say

That the training that they received on Horizon was not adequate or satisfactory I have heard that whether it was my cases or I I can’t um recollect specific examples but that does ring a bell and and if I’m honest when I trained to be a counter clerk I think it

Was uh something like two or three weeks in a classroom and then two or three weeks with somebody sat behind me watching everything I did whereas this is obviously a couple of days or one day’s training that wasn’t the message that you were seeking to convey here though

You you were providing ammo to beef up the post office’s case to Parliament yeah I don’t I don’t remember this at all what I was doing I think that’s factual it was also a par or fail course Etc um but what it doesn’t do is provide that more nuanced position that

You’ve just expressed namely look I when I was a counter Clark I spent two or three weeks being trained and that was reduced to a couple of days and then I think a day and then even less yeah um having said that these people may already have been sub poost Masters and

Clerks so they would know how to work in a post office I think this was purely The Horizon training not not the full monty of counter Clark Work by this time 2015 I realize we’re jumping right ahead at the moment were you asked to provide positive views only when making comments

On this document that was to sub be submitted to Parliament I don’t recall because I don’t recall the document would you naturally only provide ammunition for the post office’s case when making comments I don’t think so no you would express any negative uh views of horizon the training of sub postmasters the

Operation of um the system the quality of Investigations and the like too would you I’d like to have thought so yes would um post office management if we just go back to the email uh Helen Dickinson you’ll see that she was the Security operation team leader North yes do you remember her

Yes would post office management be receptive to um bad news stories about Horizon in a an exercise like this um at the time I I think my view at the time was if it was good news it was good news if it was bad news it was bad news again I don’t

Recall it but I’d like to to think that that I would have told the truth you know whichever side that fell on and you didn’t wouldn’t have felt any inhibition in 2015 of saying any um giving additions to this document that were uh negative or uncomplimentary about Horizon

I wouldn’t have an issue with that um although at the time the or the messages were that there is nothing wrong with the system um so whether that’s reflected my mindset but you know I’d like to think if I saw something that that wasn’t right I I

Would say it okay we’ll be coming back to this um uh later that can come down both those documents can come down thank you you um have told us already that you worked as an investigation manager between 2000 and 200 um 4 can we look please at poll1 6867 please

And can we start with page nine please this is part of a long email chain uh years um later in 2010 and can you see that you’re copied in on this email from um Sue lather to a um a group of people yes and can you remember who sue laa was

I think she was the head of information security and if we um that that’s completely accurate it it fits with her signature block if we um just read the start of this chain in far as you were included within it um as was disced discuss on the conference call and taking into account

Rob’s comments uh to confirm that what we’re looking at is a general due diligence exercise on the Integrity of horizon to confirm our belief in the robustness of the system and thus rebut any challenges do do you remember um this early 2010 I I don’t I don’t remember it um

But this is an example as I said of the message is that there’s nothing wrong with Horizon and that’s not having a a go at Sue I think she was in the same position as quite a few of us looking at the email there do you

Think that um you were part of that conference call probably I I can’t remember it in any event um Miss lather continues the information security team have looked at the information that’s been forwarded to them read the above and it seems that the issues raised are mainly around procedural items and about accounting

Reconciliation to enable us to examine the Integrity of horizon from an information security perspective we need input from a number of areas one a description of the accounting process from the business perspective including the interfaces between Horizon and PFS and the process by which error notices are generated the identity of

All the offices making allegations together with a list of loss uh declarations from those offices a report from Service delivery of all the problems they’ve received through the live service desk and then uh there is some attribution of actions and then at the end once we H have that information I

Can then put together a plan of how we will examine the system um integrity of Horizon and the resource required to complete it do you remember this proposal to um undertake a due diligence exercise on the Integrity of horizon the purpose of which was to confirm an

Existing belief in the robustness of the system I don’t recall it now if we go um forwards please to um page seven and scroll down please uh just scroll down a little further please uh Mr Wilson a lawyer do you remember him Rob Wilson I do yes uh it

Says I know I note you wish to examine the Integrity of horizon from an information security perspective and then just on to page nine but what does this mean yes yes and then back um to page seven please middle of the page Miss lather essentially it means we wish to

Examine the security controls we have specified for Horizon and those systems with which it interfaces are indeed in place and working uh correctly and then top of the page please Mr Wilson says we have have additional difficulties in relation to challenges to Horizon today I’ve been made aware of a prosecution being

Conducted by the CPS where Horizon is being challenged the case may have been already identified by you the difficulty however will be our lack of control over any case that is not being prosecuted by my team just stopping there before we get to the questions that arise at the

End of this chain uh in what circumstances were cases prosecuted by the CPS um I think they were few and far between um but it may be for example a sub postmaster member of staff was stealing from him and if they went directly to the police they they may investigate it

And they may wish to have the the transaction event logs or some other fitu documents to to examine and the view that Mr Wilson expresses here was that one that was circulating within the investigation Community namely that when the CPS are the prosecutors and the police the investigators there is a lack of

Control by the post office over what happens within the case I I don’t recall it being a I don’t recall this anyway but I don’t recall it being communicated to others can you recall it being a problem or being seen as a problem that I don’t recall it but

I can understand what he’s saying that yes if it’s not being dealt with by his team um it’s obviously not as good as if it were being dealt with by their team I think that’s a matter of debate but um here he’s talking about control over a case what would you understand the

Reference to control being in the context of a debate over a challenge to Horizon my view on this is that the uh legal services or criminal law team by and large would have oversight over all cases um so that I mean they could see patterns or or problems Etc if it was

Being a case of being dealt with by the police or another law enforcement agency they they wouldn’t have sight of the potential problems or issues that’s um one aspect of control namely site potentially but wouldn’t you understand control also to mean control over what is disclosed and what is not disclosed

Um I I don’t read it like that the the difficulty how however will be our lack of control if the control is about disclosure then I would imagine it’s up to the police or other law enforcement agency who is investigating the case to deal with disclosure um however having

Said that yes I accept that if the police were unaware of uh potential problems or issues with Horizon then they wouldn’t know to pursue that and disclose anything if that makes sense isn’t what Mr Wilson saying to you and the others here that look we’re planning to potentially investigate Horizon

Integrity we might have to disclose that to the police and the CPS in independently investigated and prosecuted cases we will lose control over that information yes whereas if it stays within the post office investigation team we retain control over that information yes can we go please to um page

One I should have said it the the bottom of the page please um you um say in relation to this chain can we please ensure that Rob Wilson is kept apprised of um the situation we just um read on to page three and included in any further

Meetings and updates on this subject our prosecution cases have faced an increase in challenges as well as our civil cases so the activities outlined below and indeed going forward are applicable to both um teams see you wanted Mr Wilson cited on this idea of a review a due diligence exercise on Horizon

Yes and can we see what he replied to you please page one he says if it’s thought there is a difficulty with Horizon then clearly the action set out in your memo is not only needed but um imperative the consequence however will be that to commence or to continue to

Proceed with any criminal proceedings will be inappropriate my understanding is that the Integrity of horizon data is sound and it is as a result of this that persistent challenges that have been made in court have always failed these challenges are not new and have been with us since the Inception of

Horizon as it always been the only way that defendants are left to challenge our evidence when they have stolen money or where they need to show that our figures are not correct by 2010 Mark 2010 does what Mr Wilson say in that paragraph reflect the view that you would have held

So so he he says it’s imperative that he’s he’s kept informed I I agree and that’s why I asked everyone to make sure that he’s kept in the loop um because I noticed he wasn’t copied in on some of the preceding emails um well let’s take it in stages after

Then um the third line he says his understanding is that the Integrity of horizon data is sound yes did that represent your view by 2010 yes so it’s another example as I mentioned earlier about messaging we had Sue lather saying that the system’s fine his Ro Wilson

Saying as his understanding is it’s fine um and the message from the top was similar so who consisted of the top well I’ve heard things and and seen things um about this quir inquiry that allegedly people much higher up the chain knew things or um we told there

Are problems or there might be problems I don’t know the ins and outs or who who those individuals are I can’t remember any particular um messages coming down but what I can recall is that was certainly no messages coming up saying stop investigating or stop Prosecuting so just breaking down what

You said there you can’t recall um any messages coming from the top of the organization at executive team level or similar that filtered their way down to you that there was nothing wrong with Horizon I can’t record specific messages now but that that was my understanding um and likewise we’ve got Rob Wilson

Here his understanding is that it’s fine sue lther her understanding was it’s fine um so at my level and their level higher up I think the impression was that we’ve been told that this the system’s fine or or working uh all the time correctly uh moving on it’s as a result

Of this that persistent challenges that have been made in court have always failed would that have been your understanding by 2010 yes in so far as I don’t recall any challenges being successful so if that was the case um let’s say there’s been three six 12 or 20 challenges and they’ve been unsuccessful

That that will I think that would have rightly or wrongly cemented my view that the system is okay and would it be your understanding that in all of those cases where the challenges had failed full disclosure had been given of any um system problems with Horizon I so that there was a fair

Hearing that had resulted in a dismissal to the challenge to Horizon my view back then or now back then back then I I I would have thought everything was done as it should have been had you heard of a case called concerning the clevel sub poost office involving Mrs wlson

Home I’ve heard the name clevel but I don’t know anything about it you would you have known about it by then by 2010 or is it something that you’ve heard in the inquiry I don’t know where I’ve heard of it but I’ve heard of the post office had you heard about sub

Postmasters being acquitted when they had raised the challenge to Horizon not that I recall but maybe um in let what now if I don’t recall you your view come 2010 would have been that the persistent challenges had always failed yes I can’t remember any challenges that were successful there

May have been some but I can’t remember Mr Wilson says these challenges are not new and have been with us since the Inception of horizon but were you aware that the post office had re received complaints concerning the Integrity of horizon data and challenges to Horizon data since the system’s very

Inception no um I don’t recall that and as we’ve discussed I was an investigation manager um from 2000 to 2004 so I would only have had my cases whereas the legal services team would have had oversight of all cases across the country coming into them so so they

May have been aware that there were issues at the beginning um but I don’t recall that during your tenure as the investigation manager which included part of the National Rollout uh period what was the message coming down from above as to Horizon Integrity back then I I don’t recall any

Uh mention of uh Horizon Integrity I I think it was more in later years that um it it was mentioned were you as an invest that can come down thank you um were you as an investigation manager given training in relation to uh the way that Horizon operated and

Was uh relevant to your job as an investigator I would say yes but I I can’t remember any training that was given I’m talking about bespoke training in relation to Horizon as an investigator again I would say yes but I I can’t remember the train how did investigation managers

Understand the data the varieties of data that were available for them from Horizon I don’t know how they were made aware um all I can remember is transaction and event logs um and how to get them off the system was the written instructions issue to investigators saying a key

Source of our evidence after say 2000 is going to be the Horizon system it’s new we haven’t got um any policy policy or procedure that relates to getting evidence from this thing these are this is a menu of the data that’s available um this is what it shows or this is what

It might show such data it might help you to prove a or disprove B and these are the people that you can get it from I do recall something like that but again I can’t remember it but it was very more simplified it was how to obtain the

Transaction log do ABC how to obtain an event log do XYZ and so on I think it was a one sheet of paper and was that a within your team document or was it a something that was applicable Countrywide I can’t remember and I don’t know whether it was drafted by someone

In our team or or one of the crime risk team or or even borrowed from the audit team I don’t know when you were acting as an investigation manager what determined whether you would investigate or not what were the relevant considerations for an investigation yeah um well as an investigation manager it

Would be whether my investigation team manager had allocated a case to me you tell us in your witness statement there’s no need to turn it up um it’s paragraph 43 um in relation to deciding whether and in what circumstances to investigate quote the decision was informed by a number of factors including the

Shortfall and the current resource and workloads within the teams is that correct yeah so leaving aside for the moment the amount of the alleged um shortfall and focusing on the current workloads within the team do you mean by that that the workload of the criminal investigation

And debt recovery teams played a part in deciding whether an alleged shortfall would be pursued as a crime or as a debt the the investigation team yes we had nothing to do with the um debt recovery team if I could just give you an example over the year I mean I think

When I started there was about 60 investigators um and something like nine or 10 teams and over the years that went down to two or three teams and about 20 investigators so as the staff reduced the workload didn’t reduce as much probably like most businesses and there came a time where you know

Investigators were swamped with work so did that affect the quality of the investigation that they were able to carry out it would have done if they had retained that work um but I do remember we had to be quite um hard and say right well we’re not investigation sorry we’re

Not investigating this or the other and what was the this that or the other that you wouldn’t investigate um lower value audit shortages um pension amounts over claims that were of a certain amount on um alleged shortfalls was there um what if any was the limit or the the floor

Beneath which you wouldn’t go in an investigation I I can’t remember a particular figure um but I do remember I think I put my statement about triggers and time scales I’m sorry triggers and time scales yes and can you can you now remember what the triggers were I can’t

Remember no but they did they they fluctuated um and even when we were agreed on a a trigger if someone’s gone long-term sick and um someone’s left then again that still wouldn’t be set in stone for us to investigate and not withstanding the use of these um uh

Triggers did it um nonetheless Remain the case that teams had an overstretched capacity to investigate at at times yes when when I mentioned we had n about 1960 investigators back then I think probably like other law enforcement a agencies we would investigate anything and everything that came our way uh as

Time went on staff became less so you had to prioritize more what you actually investigated was there any drop in the extent and quality of the investigations that were conducted not that I recall so quality is always remained the same I believe so it’s right isn’t it that you were set objectives to

Recover uh a certain amount a certain percentage of fraud activity weren’t you yes can we look please at poll 0012 6734 these are your um objectives for um your personal objectives for um the year April 2012 to March 2013 was this a a feature of um all of your time as um an

Investigator and and uh at this time in for all recovery uh so every year we had objectives Um I’m not sure when I was an investigator we had a Target for recoverers at this time we’re looking April 2012 March 2213 you’re a um an accredited Financial investigator yes are you saying that you don’t remember targets for Recovery in the earlier period that I was looking at 2000 to

2004 when you were an investigations manager that’s correct I think I think the recovery was important but I don’t remember it being an actual objective like it is here in 8 years and if we just scroll down and look at um box three please uh Under The Heading fraud activity return on

Investment and um fraud activity return on investment investment means investment in you does it yes um I post office saying we’re employing you to investigate um as a financial investigator losses and seek to recover them yes we are making an investment we want to see what the return is on our investment in

Employing you yes is that what that heading means I think so um and I think it says that um evidence activity that prod ues recovery rates on inquiries closed of 65% or more subject to quarterly review can you tell us what that figure means

65% or more I 65% or more of what right so 65% or more on closed cases but what what well if there’s been 10 cases in the year uh um and all of them were £10,000 losses the total is £100,000 of loss so the recovery Target would be

65,000 okay so it means that you have got to produce evidence that shows that of the total amount of shortfalls for that year are the alleged losses yeah you have recovered 65% of those yes so it doesn’t mean in 65% of cases and it does mean in um 65% of

Cases there must be some recovery it’s by reference to the total figure yes and can we see similarly for the next year poll D12 6836 these are your objectives for April 2013 to March 2014 um fraud activity return on the investment um evidence activity that produces recovery rates on closed inquiries of

65% or more so the same yeah and do you know why um it one of your performance objectives was the um recovery of such a um a number of the alleged s shortfalls the particular number I don’t know why it’s 65% um but I can understand if you’re a fin accredited Financial investigator

Your job is to get money back for the business was that a consistent thing team throughout your time as an investigator and then as an an AFI as an AFI yes as an investigator I can’t remember but that you know there was a recovery element to the

Role can we look please at poll 012 694 just pause there a moment we um looks like we may have lost the connection with the chairman sorry I was muted I was saying that there was a very small period of time no more than seconds but I think I

Lost connection but I’ve been um following all that’s happened without a problem okay so we can’t see you at the moment for um for some reason which um it’s slightly um discombobulating to hear a voice um without a a picture because we don’t know whether you here or or not well I I

I can assure everyone that I am here but um obviously it’s necessary that I that I can be seen yes you can now sir um you’re back in the room uh can we look please at this document um which looks like uh the outcome of a performance review against

The objectives that we’ve just looked at it’s dated um or it’s for the period April till October 2013 can you see that yes and if we just scroll down on the one that we’re looking at the ROI return on investment it says 72% recovery rate against closed cases across um the team

So you exceeded the 65% um Target and then you um set out the things that you did in order to do that essentially yes yes did these recovery targets getting in money impinge on the way that you and your team went about its work in relation to sub

Postmasters not that I remember no we’ve got to get the money in there’s an objective we’ve got to get the money in is is the objective um but if there is no money um I want to say it’s the luck of the draw but some cases there isn’t

Any money some cases there is what were the consequences for you in missing targets the potential consequences were don’t want to go into too much detail but on our pdrs You’ got a score of five which was excellent four was very good three was good two was

Improvement Acquired and one was poor so if if you didn’t hit the targets I might have gone from good to Improvement required so it affect Ed your PDR score uh which in turn would affect your bonus that you got as well what I was about to ask was the

Achievement of the Target in getting money in from sub postmasters linked to remuneration and the answer is yes it was linked to renumeration for me and others um but as I saidan if if let’s say that was 50% I could demonstrate well you know couldn’t get money in these cases

Because there weren’t any so I would have argued the toss if I hadn’t hit the the required Target and was um were all Financial investigators uh on a bonus scheme in the link to the recovery of money from some postmasters yes and everyone within the security team was

On uh a bonus depending on their own objectives what were the other bonus metrics for other members of the security team I I don’t know I mean a crime risk analyst that their day job is more analytics and what about a straet investigator the investigator as as I

Say I can’t recall when I was an investigator there was a a specific task Target um and I I can’t mean I can’t remember what if any Target they had in late years here you are um telling a manager presumably um in this sentence the second sentence I’ve continued to secure impressive

Recoveries um something in order to justify your bonus indeed at this time um and we’re here late 2013 had you any knowledge at all of any Horizon Integrity issues not specifically just um what if I could call it noise what um so so noise in my mind

Means something that’s going on in the background that’s a bit um annoying and um something you’d rather not pay attention to is that how you’re referring to noise no um what do you mean by Horizon Integrity issues were just noise right what I mean what is um I mean I can’t be

Specific in terms of which years but there would be some noise I people citing Horizon as the years went on there may be more offices or or people citing Horizon um it’s a bit of like a Snowball Effect it sort of gathers momentum as the years go on is

That how you viewed it that it was just momentum Gathering um rather than potentially the true picture emerging having been uh either not investigated or suppressed for a period of time yeah again I’ll be honest I I viewed it as um as you’ve outlined at the time so it’s something that was

Just Gathering momentum because it was being mentioned in the press and amongst the sub postmaster Community yes and myself and as we’ve mentioned Rob Wilson to and others um didn’t know or believe there was a problem more than that they were saying that there isn’t yes indeed did you ever

Know what their view was based on no but I presume it’s the same as mine that business with con ly saying there’s nothing wrong with it there’s nothing wrong with it which I always found a bit strange myself um why did you find it strange because my view is

That every computer system has problems or glitches so I think it was too strong to say there is nothing wrong with it and it’s working at all times I mean I’m sure we’ve all been in a supermarket um half price item you get to the till and it’s comes up as full

Price I’m sure we’ve all been on our PCS and some message comes up saying you you can’t access this you haven’t got the rights yeah I’ve not even wanted to access it on a grander scale you’ve got Air Traffic Control across the world so I mean every computer system in my view

Does have some uh issues with it so I think the post is quite strong there but that doesn’t mean that I thought there was anything systemically wrong with Horizon and that seemed to have been backed up by uh witness statements obtained by fiets presumably linking bonuses to

The amount of money that you recovered from sub postmasters was intended to affect your behavior yes um but when you say that it affected my behavior in so far as I would do what I could within the Realms of the proceeds of crime act how did it affect your behavior no

Knowing that you were on a bonus if you got more money in well even putting that aside that that was my job to get money back um and I utilized primarily confiscation orders uh which was within the Realms of the proceeds of crime act and only following a

Conviction so I utilize the powers um in the appropriate way that can come down thank you in your witness statement you tell us no need to turn it up it’s paragraphs 19 and 20 um you refer to your role in relation to case strategies and in paragraph 25 you refer

To involvement in the development or management of policies who was responsible for criminal litigation strategy at the post office I think it was the head of security and the senior security manager within that strand did you ever see um criminal litig litigation strategy described I may have seen a a policy of

Like a prosecution policy if that was the same thing I can remember it but I don’t know the details of it can you in general terms describe what the post office criminal litigation strategy was say between 200 2004 no and what about at a later stage when you were in AFI I don’t

How would you describe it now looking back at it that the one element or one focus is to recover money’s owed was that the principal purpose of the criminal litigation strategy I’m not sure it was the the principal reason um again my my recollection was that there was a policy to prosecute

Um if it was in the public interest um and you know whatever rules or guidance that needed to be followed by primarily the criminal law team the recoveries were a significant part some organizations have a um or describe themselves as having a a robust uh criminal investigation and

Prosecution policy some would say that they have a weak or tolerant criminal investigation policy or or strategy U some might impose um thresholds for investigation and prosecution that are exceedingly High um meaning that not much gets investigated or prosecuted uh where in the Spectrum did the post office sit say in

2000 to 2004 when you were an investigation manager I I don’t know cuz I can’t compare to to those all I can say is recoveries were important and they grew more important as time went on and was it explained to you why recovery of money was important seen as

Important the only thing I can recall was that different parts of the post office uh generated profits for the business whereas security investigations were more of a cost so in order to redress that balance in some way that’s why invest uh recoveries became more of a

Focus and so the the recovery of uh debt as you called it from sub postmasters was seen as a way of contributing to the post office’s bottom line yes thank you so it’s up us 12 uh I wonder whether that would be an appropriate moment to break just for half an hour

Until 1:00 yeah certainly thank you very much sir

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