much more detailed going to be a much more detailed drilling down about that. one of the other issues is going to be the issue of remote access. this was how fujitsu employees in their office in bracknell in berkshire were able to access the horizon system remotely without the knowledge of sub—postmasters. when did that start? we got some suggestion from evidence earlier this week that they could access the system remotely as early as 2002. yet, for years the post office denied that that access was possible so again, what were fujitsu telling the post office about that issue? we are going to get a lot more detailed questions. i think they could also be a question about the behaviour of fujitsu employees. because we heard some evidence yesterday about one of the cases involving the sub—postmasters league castleton. he was wrongly

accused of stealing £25,000 —— lee castleton. the only reason why he wasn't believed really was because a fujitsu employee took to the stand and said that the horizon software was operating properly. he signed a witness statement to that effect. that's why lee castleton wasn't believed. and yet we heard yesterday that one of the fujitsu managers involved in that case had sent an e—mail calling lee castleton a nasty chap who was out to rubbish the fujitsu name. italked chap who was out to rubbish the fujitsu name. i talked to lee castleton at the end of the hearing yesterday and asked for his reaction to that e—mail. he said he was surprised because he had never had any conversation with fujitsu employees, he never had any correspondence with them, he didn't know the person who had sent this e—mail. i asked know the person who had sent this e—mail. iasked him know the person who had sent this e—mail. i asked him what his thoughts were when it comes to this fujitsu manager and he said i hope

he has as many sleepless nights as i have. so he was upset by what he heard yesterday. so there could well be some questioning about the behaviour of fujitsu employees. just to give you a bit more of a background on paul patterson. he is the head of fujitsu europe, been in that role since 2019. let's remember since 2019 a lot of all of this evidence has come to light, convictions have been overturned of sub—postmasters, and an awful lot has happened since he took over. but also he's been at fujitsu for 1h years. so it's not like he's going to be able to say this morning i've onlyjust to be able to say this morning i've only just arrived at this company. one of the things he was asked about in the house of commons was about theissue in the house of commons was about the issue of compensation. what the company is saying is that they will contribute towards a compensation fund. but they are not saying how much. we are unlikely to know any figure until the end of this inquiry

which is set to run until the end of this year. which is set to run until the end of this ear. ~ _, , , ., this year. with the comments you auoted this year. with the comments you quoted from _ this year. with the comments you quoted from a _ this year. with the comments you quoted from a fujitsu _ this year. with the comments you quoted from a fujitsu employeesl this year. with the comments you i quoted from a fujitsu employees and others i have seen, there is a whiff of large company, big brand going up against small individual people. paul patterson is about to speak so let us go to the inquiry and see what he has to say. todayis today is not a rerun of the evidence that you _ today is not a rerun of the evidence that you gave to the business and trade _ that you gave to the business and trade committee on tuesday of this week, _ trade committee on tuesday of this week, not_ trade committee on tuesday of this week, not least because many of the issues _ week, not least because many of the issues addressed in your evidence to that committee will be addressed to you when_ that committee will be addressed to you when you return to give evidence in phases _ you when you return to give evidence in phases five and six of the inquiry, _ in phases five and six of the inquiry, do you understand? yes. in that connection, _ inquiry, do you understand? 19:3 in that connection, those watching inquiry, do you understand? i9:3 in that connection, those watching the proceedings should understand that simply— proceedings should understand that simply because an issue is not addressed by mr paterson today does not mean _ addressed by mr paterson today does not mean that it will not be addressed with him in due course. the inquiry—

addressed with him in due course. the inquiry undertakes its work in a forensic— the inquiry undertakes its work in a forensic manner, only asking questions _ forensic manner, only asking questions of witnesses when it is satisfied — questions of witnesses when it is satisfied that all reasonably relevant material has been obtained, so that— relevant material has been obtained, so that questions can be put on a proper— so that questions can be put on a proper evidential foundation. so you are here _ proper evidential foundation. so you are here to— proper evidential foundation. so you are here to give evidence today primarily — are here to give evidence today primarily about the issues that you address— primarily about the issues that you address irr— primarily about the issues that you address in your third witness statement, which concern ar 0 data, do understand mark kelly s. in particular— do understand mark kelly s. in particular the reliability of that data. — particular the reliability of that data. the — particular the reliability of that data, the use of it by fujitsu on the post — data, the use of it by fujitsu on the post office, the provision of it to the _ the post office, the provision of it to the office in connection to crimihai_ to the office in connection to criminal proceedings against post office _ criminal proceedings against post office employees, do understand? yes. : :. office employees, do understand? yes. : :, office employees, do understand? yes. : ., , :, , yes. and i will ask you questions about some _ yes. and i will ask you questions about some of _ yes. and i will ask you questions about some of your _ yes. and i will ask you questions about some of your second - yes. and i will ask you questions i about some of your second witness statement — about some of your second witness statement. can we start by formally introducing — statement. can we start by formally introducing the evidence in your second — introducing the evidence in your second and third statements, notley said they— second and third statements, notley said they can be made available to the public— said they can be made available to the public by the company's website. your second — the public by the company's website. your second witness statement, that

is in tab— your second witness statement, that is in tab a2 _ your second witness statement, that is in tab a2 in your hard copy bundle _ is in tab a2 in your hard copy bundle. the url for it is f uj 0012 6035 _ bundle. the url for it is f uj 0012 6035 it _ bundle. the url for it is f uj 0012 6035 it is — bundle. the url for it is f uj 0012 6035. it is dated the 29th of december 2022 and is 193 pages long, including _ december 2022 and is 193 pages long, including its appendices. if you go to page _ including its appendices. if you go to page 63, which is the last page of the _ to page 63, which is the last page of the statement itself, is that your— of the statement itself, is that your signature?— of the statement itself, is that your signature?_ are j of the statement itself, is that - your signature?_ are the your signature? yes, it is. are the contents of— your signature? yes, it is. are the contents of that _ your signature? yes, it is. are the contents of that witness _ your signature? yes, it is. are the | contents of that witness statement true to _ contents of that witness statement true to the best of your knowledge and belief— true to the best of your knowledge and belief mark true to the best of your knowledge and belief mar— true to the best of your knowledge | and belief mar_ your and belief mark yes, they are. your third witness _ and belief mark yes, they are. your third witness statement _ and belief mark yes, they are. your third witness statement which - and belief mark yes, they are. your third witness statement which is - and belief mark yes, they are. your| third witness statement which is tab a1. third witness statement which is tab at w_ third witness statement which is tab at w ”n _ third witness statement which is tab a1. w itn oh 665 zero 300. that witness — a1. w itn oh 665 zero 300. that witness statement is dated the 14th of september 2023, is 103 pages long. _ of september 2023, is 103 pages long, including its appendices and if you _

long, including its appendices and if you turn— long, including its appendices and if you turn to page 80, you should find your— if you turn to page 80, you should find your signature. is if you turn to page 80, you should find your signature.— find your signature. is that your signature? _ find your signature. is that your signature? yes, _ find your signature. is that your signature? yes, it— find your signature. is that your signature? yes, it is. _ find your signature. is that your signature? yes, it is. are - find your signature. is that your signature? yes, it is. are the l signature? yes, it is. are the contents _ signature? yes, it is. are the contents of— signature? yes, it is. are the contents of that _ signature? yes, it is. are the contents of that statement i signature? yes, it is. are the i contents of that statement true signature? yes, it is. are the - contents of that statement true to your knowledge and belief mark kelly yes, they— your knowledge and belief mark kelly yes, they are. thank you. before i ask you _ yes, they are. thank you. before i ask you questions of substance, this is the _ ask you questions of substance, this is the first— ask you questions of substance, this is the first occasion on when you have _ is the first occasion on when you have given — is the first occasion on when you have given oral evidence to the inquiry— have given oral evidence to the inquiry in — have given oral evidence to the inquiry in the first occasion on which — inquiry in the first occasion on which a — inquiry in the first occasion on which a senior fujitsu executive has given— which a senior fujitsu executive has given evidence to the inquiry. i know— given evidence to the inquiry. i know in— given evidence to the inquiry. i know in your first witness statement, which republished back on the 2nd _ statement, which republished back on the 2nd of— statement, which republished back on the 2nd of december 2022, you gave an apology _ the 2nd of december 2022, you gave an apology to sub—postmaster is and that you _ an apology to sub—postmaster is and that you said something to the equivalent effect on tuesday of this week to _ equivalent effect on tuesday of this week to parliament and since then, fujitsu _ week to parliament and since then, fujitsu is— week to parliament and since then, fujitsu is a — week to parliament and since then, fujitsu is a corporation, issued a public— fujitsu is a corporation, issued a public statement. is there anything that you _ public statement. is there anything that you would like to say in that regard _ that you would like to say in that regard now?— that you would like to say in that reaard now? , ., «r i. :, , regard now? yes, thank you. to these sub-masters — regard now? yes, thank you. to these sub-masters and _ regard now? yes, thank you. to these

sub-masters and their _ regard now? yes, thank you. to these sub-masters and their families, - regard now? yes, thank you. to these sub-masters and their families, we i sub—masters and their families, we apologise. fujitsu apologises and is sorry for our part in this appalling miscarriage ofjustice. this inquiry is examining those events forensically over many, many decades, which involved many parties, not least fujitsu in the post office but other organisations and individuals. we are determined to continue to support this inquiry and get to the truth where ever it lays and at the conclusion of the inquiry under guidance from this inquiry, engage with government on suitable compensation for the sub—postmasters and their families. can i start with your background, please _ can i start with your background, please you _ can i start with your background, please. you are a director of fujitsu — please. you are a director of fujitsu services limited, is that right? — fujitsu services limited, is that riuht? . . fujitsu services limited, is that right?_ which - fujitsu services limited, is that right?_ which | - fujitsu services limited, is that right?_ which i will i fujitsu services limited, is that. right?_ which i will call right? yes, it is. which i will call fu'itsu. i

right? yes, it is. which i will call fujitsu. ithink_ right? yes, it is. which i will call fujitsu. i think your _ right? yes, it is. which i will call fujitsu. i think your full - right? yes, it is. which i will call fujitsu. i think your full title, - fujitsu. i think your full title, according _ fujitsu. i think your full title, according to the internet and the fujitsu _ according to the internet and the fujitsu web page, is corporate executive _ fujitsu web page, is corporate executive officer, evp, is that executive _ executive officer, evp, is that executive vice president? yes, it is. executive vice president? yes, it is and _ executive vice president? yes, it is. and chief executive officer or corporate — is. and chief executive officer or corporate executive officer? it is the first one. — corporate executive officer? it 3 the first one, forgive me. corporate executive officer? it is the first one, forgive me. chiefl the first one, forgive me. chief executive _ the first one, forgive me. chief executive officer _ the first one, forgive me. chief executive officer for _ the first one, forgive me. chief executive officer for the - the first one, forgive me. chief executive officer for the europe region — executive officer for the europe reuion. . executive officer for the europe reuion. , , executive officer for the europe region._ corporate - region. yes, it is. corporate executive — region. yes, it is. corporate executive officer _ region. yes, it is. corporate executive officer for - region. yes, it is. corporate executive officer for the - region. yes, it is. corporate . executive officer for the europe region. — executive officer for the europe region, thank you. when did you join fujitsu? _ region, thank you. when did you join fujitsu? in _ region, thank you. when did you 'oin fu'itsu? :. , region, thank you. when did you 'oin fu'itsu? :, , ::' :: region, thank you. when did you 'oin fujitsua— what fl region, thank you. when did you 'oin fujitsu?_ what wash fujitsu? in early 2010. what was our first fujitsu? in early 2010. what was your first role — fujitsu? in early 2010. what was your first role and _ fujitsu? in early 2010. what was your first role and job _ fujitsu? in early 2010. what was your first role and job title? - fujitsu? in early 2010. what was your first role and job title? i - fujitsu? in early 2010. what was | your first role and job title? i was your first role and “0b title? i was hired to raise — your first role and job title? i was hired to raise sales _ your first role and job title? i —" hired to raise sales leadership role and i was this sales leader for the private sector.— private sector. what did that 'ob involve? very �* private sector. what did that 'ob involve? very much i private sector. what did that 'ob involve? very much focused h private sector. what did that job

involve? very much focused onl private sector. what did that job - involve? very much focused on new business, selling _ involve? very much focused on new business, selling two _ involve? very much focused on new business, selling two fujitsu's - business, selling two fujitsu's customers in the private sector, as was then. ~ :. :. . customers in the private sector, as was then. ~ :, .,, i. customers in the private sector, as was then. ~ :, ., ., was then. what was your title again? head of sales — was then. what was your title again? head of sales for _ was then. what was your title again? head of sales for the _ was then. what was your title again? head of sales for the private - head of sales for the private sector. we will confirm the individual titles correctly. did that role have _ individual titles correctly. did that role have any connection to all responsibility for the horizon it system? — responsibility for the horizon it system? so responsibility for the horizon it 5 stem? , ,, , responsibility for the horizon it s stem? ,, , , responsibility for the horizon it sstem? ,, , , :, system? so subsequently, my role chanced system? so subsequently, my role changed and _ system? so subsequently, my role changed and my — system? so subsequently, my role changed and my responsibility - changed and my responsibility changed. i was in a sales or sales leadership role for the uk private sector, then including the public sector, then including the public sector, and then that evolved to be a european head of sales role as well. in the early part, the middle part of that, my responsibility also included the selling of the contract, new contracts to the post office. ~ :. . :.

contract, new contracts to the post - office._ approximately office. when was that? approximately 2012, 2013, office. when was that? approximately 2012, 2013. is _ office. when was that? approximately 2012, 2013, is when _ office. when was that? approximately 2012, 2013, is when the _ office. when was that? approximately 2012, 2013, is when the post - office. when was that? approximately 2012, 2013, is when the post office - 2012, 2013, is when the post office new business selling response ability came into my responsibility. so before that, 2012, did yourjob hring _ so before that, 2012, did yourjob bring you — so before that, 2012, did yourjob bring you into connection with the horizon _ bring you into connection with the horizon it— bring you into connection with the horizon it system in any way? i horizon it system in any way? don't horizon it system in any way? i don't believe so. after - horizon it system in any way? i don't believe so. after 2012, i horizon it system in any way? i i don't believe so. after 2012, what was the extent _ don't believe so. after 2012, what was the extent of _ don't believe so. after 2012, what was the extent of your _ don't believe so. after 2012, what was the extent of your connection j don't believe so. after 2012, what i was the extent of your connection to the horizon — was the extent of your connection to the horizon it system? my connection was to the post _ the horizon it system? my connection was to the post office. _ the horizon it system? my connection was to the post office. we _ the horizon it system? my connection was to the post office. we had - the horizon it system? my connection was to the post office. we had a - was to the post office. we had a number of contracts with the post office, one of them being horizon. one of them being the telecoms contract, so their home phone and broadband contract. it was my team who were responsible for the sale of services associated with the new telecoms contract, and clearly any renewal or extension to the horizon system subsequently. did you remain in that role until

you got— did you remain in that role until you got your present position in 2019? _ 2019? no, that role zom — no, that role changed. sol zom — no, that role changed. so i became 2019? no, that role chan-ed. so i became a no, that role changed. so i became a european head of sales and business development and i did not have a direct team involved in the post office then. how long did your involvement with the post _ how long did your involvement with the post office last? i would... the post office last? iwould... fouryears, the post office last? iwould... four years, five the post office last? i would... four years, five years. in that four to five year period, let's call it between 2012 and 2014, sorry, 2016—17, how regularly were you sorry, 2016-17, how regularly were 0 :, , , , sorry, 2016-17, how regularly were you dealing with issues concerning the horizon _ you dealing with issues concerning the horizon it _ you dealing with issues concerning the horizon it system? _ the horizon it system? i the horizon it system? iwasn't _ the horizon it system? i wasn't dealing with issues... dealing with the post office account in so far— dealing with the post office account in so far as — dealing with the post office account in so far as it concerned that horizon _ in so far as it concerned that horizon it_ in so far as it concerned that horizon it system? horizon it system ? my _ horizon it system? my engagement and my sales team's

engagement was very much focused on the new business into the post office. it was not dealing with the service delivery, albeit clearly at times in those conversations, the post office may have asked me questions about service delivery and that would have been passed on to the relevant service delivery team. that was my next question, to what extent _ that was my next question, to what extent were — that was my next question, to what extent were you cited on issues or problems— extent were you cited on issues or problems with service delivery in that four— problems with service delivery in that four to five year period, so far as _ that four to five year period, so far as horizon is concerned? ithink— far as horizon is concerned? i think in— far as horizon is concerned? i think in several different meetings with post office executives when we were discussing the changes to the contract, so i think in about 2012-13 they to the contract, so i think in about 2012—13 they were looking to change the contract structure into a tower structure. in some of those meetings, we would have definitely made reference to problems, given i was in the room, and that would have been handed back into their service delivery team.

to your recollection, did any of those — to your recollection, did any of those engagements concerning data reliability, data integrity or similar— reliability, data integrity or similar issues? so _ similar issues? so in _ similar issues? so in the pack that i have got in this supplementary pack in today's hearing, there is a reference to questions asked of me and a colleague by the cio, which we passed on to, which was talking about that very point. i am not going to go into that in detail— i am not going to go into that in detail today, i am not going to go into that in detailtoday, ijust i am not going to go into that in detail today, ijust want to get an overview— detail today, ijust want to get an overview today for the purposes of the questions i will ask you subsequently of the extent to which you knew _ subsequently of the extent to which you knew of issues concerning horizon — you knew of issues concerning horizon before you became ceo in 2019 _ horizon before you became ceo in 2019 0r— horizon before you became ceo in 2019. orwhetheryou horizon before you became ceo in 2019. or whether you are coming to these _ 2019. or whether you are coming to theseissues 2019. or whether you are coming to these issues completely afresh in 2019 _ these issues completely afresh in 2019. what would be the answer to that? _ that? in- that? in 2019 in my that? — in 2019 in my appointment, i was that?

in 2019 in my appointment, i was of course aware that there were issues regarding prosecutions. clearly there was the public case as well, so i was aware on a personal level there were issues with the prosecutions. so i was aware of those topics. before you became ceo in 2019? those topics. before ou became ceo in 2019? . before you became ceo in 2019? yes. i think the e-mail _ before you became ceo in 2019? yes. i think the e-mail you _ before you became ceo in 2019? i93 i think the e—mail you are referring to, i_ i think the e—mail you are referring to, iwon't— i think the e—mail you are referring to, wont go— i think the e—mail you are referring to, i won't go into it in detail today, — to, i won't go into it in detail today, shows you had some involvement in and were briefed about— involvement in and were briefed about the — involvement in and were briefed about the second site investigations?- about the second site . investigations?- and about the second site - investigations?- and the about the second site investigations? yes. and the impact of those in investigations? i93 and the impact of those in fujitsu? investigations? yes. and the impact of those in fujitsu? yes. _ investigations? yes. and the impact of those in fujitsu? yes. and - investigations? yes. and the impact of those in fujitsu? yes. and so - of those in fu'itsu? yes. and so overall of those in fu'itsu? yes. and so ovetau we — of those in fujitsu? yes. and so overall we shouldn't _ of those in fujitsu? i93 and so overall we shouldn't get the impression when we listen to your evidence _ impression when we listen to your evidence in— impression when we listen to your evidence in a moment that you came to all— evidence in a moment that you came to all of— evidence in a moment that you came to all of the — evidence in a moment that you came to all of the issues concerning data integrity. _ to all of the issues concerning data integrity, the provision of information and evidence by fujitsu to the _ information and evidence by fujitsu to the post— information and evidence by fujitsu to the post office and post office prosecutions afresh when you became ceo in _ prosecutions afresh when you became ceo in 2019?

i joined, ceo in 2019? ijoined, as we already discussed, i joined in 2010 and certainly through my career inside the company laterally i became more and more aware of the issues, including during this inquiry, becoming more and more aware at a very detailed level. ca n level. can i turn to your second witness statement, — can i turn to your second witness statement, please? f uj 00126035. it will come — statement, please? f uj 00126035. it will come up on the screen for you. this is your second witness statement. you will see at the top, it is stated. — statement. you will see at the top, it is stated, as we have established already. _ it is stated, as we have established already, the 29th of december 2022. so 13 months ago or so. if we look at paragraph three, paragraphs one and two _ at paragraph three, paragraphs one and two are usually introductions, but paragraph three at the foot of

the page... as noted in your first corporate — the page... as noted in your first corporate witness statement, you do not have _ corporate witness statement, you do not have first—hand knowledge of many _ not have first—hand knowledge of many of — not have first—hand knowledge of many of the matters set out in statement. you wish to reiterate at the outset — statement. you wish to reiterate at the outset how the information in the outset how the information in the statement has been compiled. you have been— the statement has been compiled. you have been assisted by a team of individuals within fujitsu and morrison _ individuals within fujitsu and morrison forster and they are the solicitors — morrison forster and they are the solicitors to fujitsu for the purposes of this inquiry, is that right? — purposes of this inquiry, is that ritht? . �* purposes of this inquiry, is that ritht? , �* ., ., , purposes of this inquiry, is that ritht? , �* :, ., right? yes. blue mat that is because ofthe right? yes. blue mat that is because of the vast amount _ right? yes. blue mat that is because of the vast amount of— right? yes. blue mat that is because| of the vast amount of documentation and sources that have to be reviewed over a period — and sources that have to be reviewed over a period of _ and sources that have to be reviewed over a period of 25 _ and sources that have to be reviewed over a period of 25 years. _ and sources that have to be reviewed over a period of 25 years. this - and sources that have to be reviewed over a period of 25 years. this team | over a period of 25 years. this team has provided — over a period of 25 years. this team has provided to me the documents referenced, you give some reference numbers— referenced, you give some reference numbers and exhibit 640 documents to this witness _

numbers and exhibit 640 documents to this witness statement, and which are the _ this witness statement, and which are the principal source of my knowledge of this statement's contents. so the information in the statement — contents. so the information in the statement that you are given is principally drawn from documents that have — principally drawn from documents that have been provided to you by your team, — that have been provided to you by yourteam, essentially? that have been provided to you by your team, essentially?— your team, essentially? correct. paragraph _ your team, essentially? correct. paragraph four. _ your team, essentially? correct. paragraph four, please. - you say responses to questions set out in — you say responses to questions set out in the _ you say responses to questions set out in the statement are generally drawn— out in the statement are generally drawn from documentary sources. these _ drawn from documentary sources. these documents have been exhibited and are _ these documents have been exhibited and are referenced. the response is provided _ and are referenced. the response is provided in— and are referenced. the response is provided in the second statement, fujitsu's— provided in the second statement, fujitsu's current understanding of the material available, given preparations for phase three were still going it may mean fujitsu may need _ still going it may mean fujitsu may need to— still going it may mean fujitsu may need to supplement their says that

the material is made available to core participants. i the material is made available to core participants. lam the material is made available to core participants. i am going to skip over— core participants. i am going to skip over paragraphs five to 189 of this witness statement, some 60 pages _ this witness statement, some 60 pages of— this witness statement, some 60 pages of the witness statement, which _ pages of the witness statement, which concerns phase three issues in the inquiry— which concerns phase three issues in the inquiry and about which we heard many— the inquiry and about which we heard many weeks of evidence back at the end of— many weeks of evidence back at the end of 2022 and the beginning of 2025 _ end of 2022 and the beginning of 2025 so— end of 2022 and the beginning of 2023. so primary evidence from the witness _ 2023. so primary evidence from the witness is _ 2023. so primary evidence from the witness is concerned. can we pick up please _ witness is concerned. can we pick up please what — witness is concerned. can we pick up please what you say on page 61 of the witness statement? at the foot of the page, please, page _ at the foot of the page, please, page 61. — at the foot of the page, please, page 61, that is it. knowledge and rectification of bugs. this section of the _ rectification of bugs. this section of the statement, indeed right to the end _ of the statement, indeed right to the end of— of the statement, indeed right to the end of the statement, addresses fujitsu's— the end of the statement, addresses fujitsu's knowledge of and rectification of bugs in the horizon system, _ rectification of bugs in the horizon system, is — rectification of bugs in the horizon system, is that right?_

rectification of bugs in the horizon | system, is that right?_ and system, is that right? correct. and ou sa , system, is that right? correct. and you say. as — system, is that right? correct. and you say, as explained _ system, is that right? correct. and you say, as explained in _ system, is that right? correct. and you say, as explained in fujitsu's i you say, as explained in fujitsu's opening — you say, as explained in fujitsu's opening statement, no complex it system _ opening statement, no complex it system will ever be completely free of hugs, _ system will ever be completely free of bugs, errors and defects. the monitoring — of bugs, errors and defects. the monitoring systems and processes seek to _ monitoring systems and processes seek to identify faults, log them as incidents— seek to identify faults, log them as incidents and then work to resolve them _ incidents and then work to resolve them following the agreed incident management process. fujitsu also relies _ management process. fujitsu also relies on _ management process. fujitsu also relies on incidents being reported by the _ relies on incidents being reported by the post office. many thousands of incidents have been logged since the inception of horizon. then over the inception of horizon. then over the page. _ the inception of horizon. then over the page, please. further down the page _ the page, please. further down the page. paragraphs 191 and 192. in relation — page. paragraphs 191 and 192. in relation to— page. paragraphs 191 and 192. in relation to the 29 bugs, errors and defects— relation to the 29 bugs, errors and defects listed by mrjustice fraser in appendix one to the rise issues judgment. — in appendix one to the rise issues judgment, the inquiry has asked fujitsu _ judgment, the inquiry has asked

fujitsu to — judgment, the inquiry has asked fujitsu to provide details relating to the _ fujitsu to provide details relating to the identification, investigation, communication and resolution— investigation, communication and resolution of the bugs, errors and defects _ resolution of the bugs, errors and defects in— resolution of the bugs, errors and defects. in february 2021, fujitsu help to _ defects. in february 2021, fujitsu help to prepare a report for post office _ help to prepare a report for post office limited in relation to the 29 bugs, _ office limited in relation to the 29 bugs, errors and defects identified by mr— bugs, errors and defects identified by mrjustice fraser. the bugs, errors— by mrjustice fraser. the bugs, errors and _ by mrjustice fraser. the bugs, errors and defects report has been disclosed — errors and defects report has been disclosed to participants and exhibited as your exhibit 260. so the sequence of events, so we can -et the sequence of events, so we can get that— the sequence of events, so we can get that clear and decode things, is mrjustice _ get that clear and decode things, is mrjustice fraser produces his horizon — mrjustice fraser produces his horizon issuesjudgment. that is also known as document number six, and that— also known as document number six, and that was— also known as document number six, and that was in december 2019, correct? — and that was in december 2019, correct? :, : and that was in december 2019, correct?- 16th _ and that was in december 2019, correct?- 16th of - and that was in december 2019, i correct?- 16th of december correct? correct. 16th of december 2019. that contained _ correct? correct. 16th of december 2019. that contained a _ correct? correct. 16th of december 2019. that contained a number- correct? correct. 16th of december 2019. that contained a number of. 2019. that contained a number of findings _ 2019. that contained a number of findings of— 2019. that contained a number of findings of fact, both in the body of the _ findings of fact, both in the body of the judgment and in an appendix

to the— of the judgment and in an appendix to the judgment, called appendix one, which you reference here, as to the existence — one, which you reference here, as to the existence of bugs, errors and defects— the existence of bugs, errors and defects in— the existence of bugs, errors and defects in the horizon system. that is both, _ defects in the horizon system. that is both, is— defects in the horizon system. that is both, is this right, legacy horizon _ is both, is this right, legacy horizon and horizon online? | horizon and horizon online? believe horizon and horizon online? i believe so. he _ horizon and horizon online? i believe so. he analyses - horizon and horizon online? i| believe so. he analyses those horizon and horizon online? i. believe so. he analyses those 29 bus, believe so. he analyses those 29 bugs. errors _ believe so. he analyses those 29 bugs, errors and _ believe so. he analyses those 29 bugs, errors and defects - believe so. he analyses those 29 bugs, errors and defects in - believe so. he analyses those 29 bugs, errors and defects in 418 l bugs, errors and defects in 418 pages — bugs, errors and defects in 418 pages of— bugs, errors and defects in 418 pages of hisjudgment in appendix one of— pages of hisjudgment in appendix one of his — pages of hisjudgment in appendix one of hisjudgment, amounting to some _ one of hisjudgment, amounting to some 105— one of hisjudgment, amounting to some 105 pages of closely typed text~ _ some 105 pages of closely typed text. then the next event is the event _ text. then the next event is the event you — text. then the next event is the event you referred to in february 2021. _ event you referred to in february 2021, a _ event you referred to in february 2021, a report by fujitsu to the post _ 2021, a report by fujitsu to the post office, that is the 22nd of february — post office, that is the 22nd of february 2021. so a year and three months _ february 2021. so a year and three months after the judgment. fujitsu writing _ months after the judgment. fujitsu writing a _ months after the judgment. fujitsu writing a report to the post office. what _ writing a report to the post office. what you — writing a report to the post office. what you understand the purpose of that report _ what you understand the purpose of that report to have been? i am

what you understand the purpose of that report to have been?— that report to have been? i am not tuite sure that report to have been? i am not quite sure i— that report to have been? i am not quite sure i understand _ that report to have been? i am not quite sure i understand the - quite sure i understand the question. mr quite sure i understand the question-— quite sure i understand the tuestion. ~, ,: . , question. mrjustice fraser produces hisjudgment — question. mrjustice fraser produces hisjudgment and — question. mrjustice fraser produces hisjudgment and finds _ question. mrjustice fraser produces hisjudgment and finds the - question. mrjustice fraser produces| hisjudgment and finds the existence his judgment and finds the existence of 29 bugs, errors and defects, spends — of 29 bugs, errors and defects, spends 105 pages analysing them in 13 months— spends 105 pages analysing them in 13 months later, fujitsu writer report — 13 months later, fujitsu writer report to _ 13 months later, fujitsu writer report to the post office about those — report to the post office about those 29 — report to the post office about those 29 bugs, errors and defects. i was asking — those 29 bugs, errors and defects. i was asking what was your understanding of the purpose of the writing _ understanding of the purpose of the writing of— understanding of the purpose of the writing of that report? in understanding of the purpose of the writing of that report?— writing of that report? in the company's — writing of that report? in the company's second _ writing of that report? in the company's second corporate | compa ny�*s second corporate statement, company's second corporate statement, we lay out details on the 29. , . :, :, ., ., 29. yes, i will come to that in a moment- _ 29. yes, i will come to that in a moment- i _ 29. yes, i will come to that in a moment. i don't _ 29. yes, i will come to that in a moment. i don't know, - 29. yes, i will come to that in a moment. i don't know, i'm - 29. yes, i will come to that in a i moment. i don't know, i'm afraid. 29. yes, i will come to that in a - moment. i don't know, i'm afraid. i have not moment. i don't know, i'm afraid. i have rrot seen _ moment. i don't know, i'm afraid. i have not seen the _ moment. i don't know, i'm afraid. i have not seen the physical - moment. i don't know, i'm afraid. i have not seen the physical report. | have not seen the physical report. it is one of the exhibits to your statement, number260. iwill it is one of the exhibits to your statement, number 260. i will not display— statement, number 260. i will not display it — statement, number 260. i will not display it at the moment. but ijust want to— display it at the moment. but ijust want to understand when the judge has found _ want to understand when the judge has found the existence of these 29

bugs, _ has found the existence of these 29 bugs, why— has found the existence of these 29 bugs, why a year and a month later fujitsu _ bugs, why a year and a month later fujitsu is— bugs, why a year and a month later fujitsu is writing a report to the post _ fujitsu is writing a report to the post office about those 29 bugs. | post office about those 29 bugs. i don't know. ok. _ post office about those 29 bugs. i don't know. ok. let's _ post office about those 29 bugs. i don't know. ok. let's move - post office about those 29 bugs. i don't know. ok. let's move on . don't know. ok. let's move on an a . don't know. ok. let's move on anyway. paragraph _ don't know. ok. let's move on anyway. paragraph 193 - don't know. ok. let's move on anyway. paragraph 193 of- don't know. ok. let's move on anyway. paragraph 193 of your| anyway. paragraph 193 of your witness — anyway. paragraph 193 of your witness statement. you say, in addition to the bugs, errors— you say, in addition to the bugs, errors and — you say, in addition to the bugs, errors and defects report, the february— errors and defects report, the february 2021 report, fujitsu has set out _ february 2021 report, fujitsu has set out in — february 2021 report, fujitsu has set out in appendix one, that is appendix — set out in appendix one, that is appendix one to this very witness statement, a series of summaries addressing — statement, a series of summaries addressing each of the 29 bugs, errors— addressing each of the 29 bugs, errors and — addressing each of the 29 bugs, errors and defects and any sub—issues identified within those classifications. the bugs, errors and defects report and summaries set out in _ and defects report and summaries set out in appendix one seek to build on the technical appendix, that is mr justice _ the technical appendix, that is mr justice fraser, and have been prepared _ justice fraser, and have been prepared by reference to a variety of sources — prepared by reference to a variety of sources. these summaries are

indicative — of sources. these summaries are indicative of— of sources. these summaries are indicative of amongst other things, the investigation of each issue, the resolution— the investigation of each issue, the resolution of each issue, communication with other parties, including _ communication with other parties, including post office limited and wider— including post office limited and wider management, and the impact on branches _ wider management, and the impact on branches. 194, please. the summaries in appendix — 194, please. the summaries in appendix one are based on a review of contemporaneous documents, primarily— of contemporaneous documents, primarily in the form of pinnacles, pi-s primarily in the form of pinnacles, pigs and _ primarily in the form of pinnacles, pigs and cows which have been identified as relevant to the relevant bugs, errors and defects. the summary should be read in conjunction with these underlying records — conjunction with these underlying records. that can come down, thank you _ records. that can come down, thank you in— records. that can come down, thank you. in appendix one to this witness statement, — you. in appendix one to this witness statement, you have set out 29 summaries relating to the 29 bugs, errors— summaries relating to the 29 bugs, errors and — summaries relating to the 29 bugs, errors and defects found to have existed — errors and defects found to have existed by— errors and defects found to have existed by mrjustice fraser, correct? _ existed by mrjustice fraser, correct? :, : existed by mrjustice fraser,

correct?- i— existed by mrjustice fraser, correct?- i am - existed by mrjustice fraser, correct?- i am going | existed by mrjustice fraser, i correct?- i am going to existed by mrjustice fraser, - correct?- i am going to look correct? correct. i am going to look throu~h correct? correct. i am going to look through some _ correct? correct. i am going to look through some examples _ correct? correct. i am going to look through some examples of - correct? correct. i am going to look through some examples of those, l correct? correct. i am going to look through some examples of those, i | through some examples of those, i won't _ through some examples of those, i won't go _ through some examples of those, i won't go through all 29, in a moment, _ won't go through all 29, in a moment, so we can see what they look like l'm _ moment, so we can see what they look like l'm the _ moment, so we can see what they look like i'm the kind of things they tell us — like i'm the kind of things they tell us. but all of this information, would you agree, was available _ information, would you agree, was available to — information, would you agree, was available to fujitsu, indeed to you, because _ available to fujitsu, indeed to you, because it — available to fujitsu, indeed to you, because it is in your witness statement, written in december 2022, but also _ statement, written in december 2022, but also earlier than that in the bugs, _ but also earlier than that in the bugs, errors and defects reported february— bugs, errors and defects reported february 2021?— february 2021? yes, because the information _ february 2021? yes, because the information is _ february 2021? yes, because the information is there. _ february 2021? yes, because the information is there. that - february 2021? yes, because the information is there. that is - february 2021? yes, because the information is there. that is how| february 2021? yes, because the i information is there. that is how we produced the report, we've produced the documents in the second statement, correct. 50 the documents in the second statement, correct.- the documents in the second statement, correct. so in terms of something — statement, correct. so in terms of something you _ statement, correct. so in terms of something you said _ statement, correct. so in terms of something you said at _ statement, correct. so in terms of something you said at the - statement, correct. so in terms of. something you said at the beginning of your— something you said at the beginning of your evidence today about the inquiry _ of your evidence today about the inquiry examining complex issues and fujitsu _ inquiry examining complex issues and fujitsu wanting to wait until essentially they inquiry has reported, in relation to this issue,

and i_ reported, in relation to this issue, and i am _ reported, in relation to this issue, and i am not — reported, in relation to this issue, and i am not saying for a moment that the _ and i am not saying for a moment that the fujitsu summaries of the bugs, _ that the fujitsu summaries of the bugs, errors and defects are complete or should be taken to be the final— complete or should be taken to be the final word on each bug, error or defect. _ the final word on each bug, error or defect. but — the final word on each bug, error or defect, but from fujitsu's perspective, is this right, as a company— perspective, is this right, as a company for the last couple years it has known — company for the last couple years it has known of the existence of these bugs, _ has known of the existence of these bugs, errors— has known of the existence of these bugs, errors and defects at a corporate _ bugs, errors and defects at a corporate level?— bugs, errors and defects at a corporate level? yes. all of the bu . s and corporate level? yes. all of the bugs and errors _ corporate level? yes. all of the bugs and errors have _ corporate level? yes. all of the bugs and errors have been i corporate level? yes. all of the i bugs and errors have been known at one level or not for many, many years. right from the very start of deployment of this system, there were bugs, errors and defects which were bugs, errors and defects which were well known. to all parties. you a t ree, were well known. to all parties. you atree, i were well known. to all parties. you agree. ithink. _ were well known. to all parties. you agree, ithink, therefore, if we

take _ agree, ithink, therefore, if we take the — agree, ithink, therefore, if we take the fujitsu summaries read together— take the fujitsu summaries read together with the bugs, errors and defects— together with the bugs, errors and defects report as a baseline, it follows — defects report as a baseline, it follows that at a senior level in the company for the last couple years— the company for the last couple years there has been corporate knowledge of the existence of these bugs? _ knowledge of the existence of these bugs? l _ knowledge of the existence of these bus? :. knowledge of the existence of these buts? ., ~' :, knowledge of the existence of these bus? :, «r :, ., knowledge of the existence of these bus? :, «r :, , knowledge of the existence of these bus? :, «r :, ., , , , bugs? i have known about these bugs because i have _ bugs? i have known about these bugs because i have seen _ bugs? i have known about these bugs because i have seen the _ bugs? i have known about these bugs because i have seen the report, i bugs? i have known about these bugs because i have seen the report, yes, | because i have seen the report, yes, would be my answer. 50 because i have seen the report, yes, would be my answer.— would be my answer. so there is no need to wait — would be my answer. so there is no need to wait for _ would be my answer. so there is no need to wait for the _ would be my answer. so there is no need to wait for the conclusion i would be my answer. so there is no need to wait for the conclusion of i need to wait for the conclusion of this inquiry— need to wait for the conclusion of this inquiry to find out at least this inquiry to find out at least this information because it is already— this information because it is already known to fujitsu? already known to fu'itsu? correct and it is in _ already known to fu'itsu? correct and it is in the i already known to fujitsu? correct and it is in the statement, - already known to fujitsu? correct. and it is in the statement, correct. can we go to the examples then, please? — can we go to the examples then, please? i— can we go to the examples then, please? i am going to look at four or five _ please? i am going to look at four or five of— please? i am going to look at four or five of the 29 bugs. can we start by looking — or five of the 29 bugs. can we start by looking at page 102 of the witness _ by looking at page 102 of the witness statement, please?

can we look at page 102 and 103 at the same _ can we look at page 102 and 103 at the same time, please? that looks like that will not be possible _ that looks like that will not be possible. ijust wanted to get... oh. _ possible. ijust wanted to get... oh. thank— possible. ijust wanted to get... oh, thank you. this is what the appendices look like in your comment to your— appendices look like in your comment to your witness statement. it lists the relevant bug, error or defect, this is— the relevant bug, error or defect, this is a _ the relevant bug, error or defect, this is a calendar square bug, then

there _ this is a calendar square bug, then there are _ this is a calendar square bug, then there are a — this is a calendar square bug, then there are a series of bullet points, sometimes — there are a series of bullet points, sometimes less than this, sometimes more _ sometimes less than this, sometimes more than _ sometimes less than this, sometimes more than this, setting out in very summary— more than this, setting out in very summary form fujitsu's position on it, summary form fujitsu's position on it. is— summary form fujitsu's position on it. is that _ summary form fujitsu's position on it, is that right? summary form fu'itsu's position on it, is that tight?— summary form fujitsu's position on it, is that right? yes. and bullet toint that it, is that right? yes. and bullet point that always _ it, is that right? yes. and bullet point that always is _ it, is that right? i93 and bullet point that always is first says documents relating to fujitsu's knowledge, rectification of the issue. — knowledge, rectification of the issue, including pinnacles, pigs and cows— issue, including pinnacles, pigs and cows are _ issue, including pinnacles, pigs and cows are set — issue, including pinnacles, pigs and cows are set out in appendix two and the relevant — cows are set out in appendix two and the relevant exhibits are given. it is taking us to the relevant exhibits _ it is taking us to the relevant exhibits and here there are about 25. :, . exhibits and here there are about 25. :, : i exhibits and here there are about 25. t, . i am exhibits and here there are about 25-- i am rrot _ exhibits and here there are about 25.- i am not on - exhibits and here there are about 25.- i am not on each i 25. correct. i am not on each occasion — 25. correct. i am not on each occasion going _ 25. correct. i am not on each occasion going to _ 25. correct. i am not on each occasion going to go - 25. correct. i am not on each occasion going to go back i 25. correct. i am not on each| occasion going to go back and 25. correct. i am not on each i occasion going to go back and look at the _ occasion going to go back and look at the underlying material. if we canjust — at the underlying material. if we can just read at the underlying material. if we canjust read through at the underlying material. if we can just read through the at the underlying material. if we canjust read through the calendar square _ canjust read through the calendar square bug. you say a problem

existed — square bug. you say a problem existed in— square bug. you say a problem existed in the horizon, whereby on occasion, _ existed in the horizon, whereby on occasion, a — existed in the horizon, whereby on occasion, a lock was not released and a _ occasion, a lock was not released and a second process would then wait for a given— and a second process would then wait fora given time and a second process would then wait for a given time before it timed out and reported in error, saying it could _ and reported in error, saying it could not— and reported in error, saying it could not proceed. the problem could occur— could not proceed. the problem could occur in _ could not proceed. the problem could occur in various places on the rise in applications, in the initial occurrences a reboot of the counter allowed _ occurrences a reboot of the counter allowed the system to resume proper function _ allowed the system to resume proper function with no data lost. then a third _ function with no data lost. then a third bullet — function with no data lost. then a third bullet point, in some cases, the calendar square branch in particular, the lock problem caused data to _ particular, the lock problem caused data to be — particular, the lock problem caused data to be lost when carrying out transfers — data to be lost when carrying out transfers between different stock units, _ transfers between different stock units, thereby causing receipts and payments— units, thereby causing receipts and payments mismatches. so this is a bug. _ payments mismatches. so this is a bug. would — payments mismatches. so this is a bug, would you agree, that has a real impact— bug, would you agree, that has a real impact on balancing, because it causes _ real impact on balancing, because it causes receipts and payments mismatches?— causes receipts and payments mismatches?- and i causes receipts and payments mismatches? yes. and the fourth bullet point. _ mismatches? yes. and the fourth bullet point, there _

mismatches? i93 and the fourth bullet point, there appear to have been _ bullet point, there appear to have been instances of these repulsed