although by the standards of some inquiries that is a comparatively short period of time, i am unshakeable in my belief that this inquiry should not last for a day longer than is strictly necessary. and if that means that the pace at which we proceed causes significant work pressures for us all, then i'm afraid that's a price we are all going to have to pay. so thank you for your words, and i think we are ready for some evidence. just before we do that, — ready for some evidence. just before we do that. can _ ready for some evidence. just before we do that, can i _ ready for some evidence. just before we do that, can i turn _ ready for some evidence. just before we do that, can i turn to _ ready for some evidence. just before we do that, can i turn to a _ ready for some evidence. just before we do that, can i turn to a brighter i we do that, can i turn to a brighter note? . ~' ,, we do that, can i turn to a brighter note? . ~ ,, as we do that, can i turn to a brighter note?_ as you - we do that, can i turn to a brighter note?_ as you know, i we do that, can i turn to a brighterl note?_ as you know, and note? thank you. as you know, and has been publicly _ note? thank you. as you know, and has been publicly announced - note? thank you. as you know, and has been publicly announced by - note? thank you. as you know, and has been publicly announced by the | has been publicly announced by the inquiry on the 9th ofjanuary this year, the inquiryjointly appointed dame sandra dawson and doctor katie stuart to the role of government

expert witnesses. dame sandra is professor emeritus of management studies at the university college cambridge and a fellow, for me the minister of sidney sussex college cambridge. she acted as an expert member on organisation governance and leadership on the expert advisory group on the windrush lessons learned review and regularly advises on leadership governance and organisation structure. doctor stuart is a public policy expert and a visiting scholar at sidney sussex couege a visiting scholar at sidney sussex college cambridge. dame sandra and doctor stuart have been instructed to produce two reports addressing issues related to leadership, management and governance. the first of those reports has been disclosed to core participant dated the 27th of march 2024 and has the url in ex pg 606. it sets out the expected and

best practice in relation for standards of governance, management and leadership in companies such as the post office in the period 1999 to 2019. it is a substantial body of work, being 133 pages in length, including appendices. a copy of that report, the first report, is to be treated as having been read into the record today and therefore a copy will be uploaded to the inquiry website today.— will be uploaded to the inquiry website today. dame sandra and doctor steward _ website today. dame sandra and doctor steward will _ website today. dame sandra and doctor steward will consider - website today. dame sandra and doctor steward will consider the | doctor steward will consider the evidence given in phases five and six of the inquiry, both written and oral evidence, and will produce a secondary report in light of that evidence when phases five and six have concluded. thank you. we can all agree that is a brighter note. yellow mechanical alan bates, please. of course, has appeared. ——

can i call alan bates, please? i swear by almighty god... i can i call alan bates, please? i. swear by almighty god... i swear can i call alan bates, please? i- swear by almighty god... i swear by almiuh swear by almighty god... i swear by almighty god _ swear by almighty god... i swear by almighty god that _ swear by almighty god... i swear by almighty god that the _ swear by almighty god... i swear by almighty god that the evidence - swear by almighty god... i swear by almighty god that the evidence i - almighty god that the evidence i shall give shall be the truth, the whole _ shall give shall be the truth, the whole truth and nothing but the truth _ whole truth and nothing but the truth. thank you very much. good morning, mr bates. my name is jason beer, and i ask questions on behalf of the inquiry. can you tell us your full name please. mali us your full name please. alan bates. thank _ us your full name please. alan bates. thank you _ us your full name please. alan bates. thank you very - us your full name please. alan bates. thank you very much i us your full name please. alan | bates. thank you very much for previously _ bates. thank you very much for previously providing _ bates. thank you very much for previously providing a - bates. thank you very much for - previously providing a comprehensive and detailed witness statement to the inquiry and for coming to london today to give evidence to insist that it might assist the inquiry and its work. can we start by looking at your witness statement. it is the only hard copy document i will ask you to refer to. it has for the purposes of the transcript that you are in w itn, 3050500 has top edges

up are in w itn, 3050500 has top edges up on the screen. it is 59 pages long excluding the exhibits page and estate dated the 29th of february. i picked up a couple of typos and i were the weather we can correct them first. on page 23, and the foot of page 23, paragraph 75. it says the cw were not involved in this period as i recall. the nfs p in the letter, should that save from colin baker? , , ., letter, should that save from colin baker?_ cross - letter, should that save from colin baker?_ cross out i letter, should that save from colin i baker?_ cross out the baker? yes, it should. cross out the janua baker? yes, it should. cross out the january 200 — baker? yes, it should. cross out the january 200 and _ baker? yes, it should. cross out the january 200 and put _ baker? yes, it should. cross out the january 200 and put in _ baker? yes, it should. cross out the january 200 and put in the - baker? yes, it should. cross out the january 200 and put in the word - january 200 and put in the word baker. , , . , january 200 and put in the word baker-_ page - january 200 and put in the word baker._ page 32. - baker. yes please. page 32. paragraph — baker. yes please. page 32. paragraph 102. _

it says in my letter dated the 9th of september 2009. i think that should be 2004. the of september 2009. i think that should be 2004.— of september 2009. i think that should be 2004. ., ., should be 2004. the original letter? yes, it should be 2004. the original letter? yes. it would — should be 2004. the original letter? yes, it would be. _ should be 2004. the original letter? yes, it would be. cannot— should be 2004. the original letter? yes, it would be. cannot be - yes, it would be. cannot be corrected — yes, it would be. cannot be corrected to _ yes, it would be. cannot be corrected to 2004 - yes, it would be. cannot be corrected to 2004 question | yes, it would be. cannot be - corrected to 2004 question mark thank you. if you turn to page 59 in the hard copy. do we see your signature there?— the hard copy. do we see your - signature there?_ and signature there? yes, you do. and were those — signature there? yes, you do. and were those two — signature there? yes, you do. and were those two typos _ signature there? yes, you do. and were those two typos correct - were those two typos correct corrected the best of your knowledge belief? , . corrected the best of your knowledge belief?_ thank _ corrected the best of your knowledge belief?_ thank you. - corrected the best of your knowledge belief?_ thank you. i - corrected the best of your knowledge belief?_ thank you. i will i belief? they are. thank you. i will not ask questions _ belief? they are. thank you. i will not ask questions about _ belief? they are. thank you. i will not ask questions about every - belief? they are. thank you. i will i not ask questions about every aspect of your witness statement because it is long and detailed and a copy of it will be uploaded to the inquiry website today so the public can read it. can i start, the statement can come down, please. starting with a little bit about your background. you tell us in your witness

statement, paragraph five, before you became a subpostmaster you worked for 12 years in the heritage and leisure project management sector. and leisure pro'ect management sector. . �* , and leisure pro'ect management sector. ., �*, . is and leisure pro'ect management methan- and leisure pro'ect management ”duh is it right| sector. that's correct. is it right that in the _ sector. that's correct. is it right that in the course _ sector. that's correct. is it right that in the course of— sector. that's correct. is it right that in the course of that - sector. that's correct. is it right that in the course of that work i sector. that's correct. is it right i that in the course of that work you developed experience in electronic point of sale systems? yes. developed experience in electronic point of sale systems?— point of sale systems? yes, i did. you developed — point of sale systems? yes, i did. you developed experience - point of sale systems? yes, i did. you developed experience in - point of sale systems? yes, i did. you developed experience in the. you developed experience in the developed of site business software and the provision of staff it training? and the provision of staff it trainin: ? , and the provision of staff it training?— and the provision of staff it traininu? , ., �*, . training? yes, that's correct. to what extent _ training? yes, that's correct. to what extent if _ training? yes, that's correct. to what extent if any _ training? yes, that's correct. to what extent if any did _ training? yes, that's correct. to what extent if any did that - what extent if any did that background assist you when you became a subpostmaster and were later required to work with the horizon it system? i later required to work with the horizon it system?— later required to work with the horizon it system? i think when horizon it system? i think when horizon came — horizon it system? i think when horizon came in, _ horizon it system? i think when horizon came in, i— horizon it system? i think when horizon came in, i was- horizon it system? i think when horizon came in, i was quite - horizon came in, i was quite positive _ horizon came in, i was quite positive about it because i knew what _ positive about it because i knew what technology in these sorts of systems — what technology in these sorts of systems could do. i was quite positive _ systems could do. i was quite positive. but i've found it a bit frustrating once the system was

installed — frustrating once the system was installed and we were operating. i found _ installed and we were operating. i found there were many shortcomings in the _ found there were many shortcomings in the system. knowing what these systems _ in the system. knowing what these systems could do, itjust seemed a bit of— systems could do, itjust seemed a bit of a _ systems could do, itjust seemed a bit of a lost — systems could do, itjust seemed a bit of a lost opportunity. you systems could do, itjust seemed a bit of a lost opportunity.— bit of a lost opportunity. you were a subpostmaster _ bit of a lost opportunity. you were a subpostmaster i _ bit of a lost opportunity. you were a subpostmaster i think _ bit of a lost opportunity. you were a subpostmaster i think between l bit of a lost opportunity. you were i a subpostmaster i think between the sist a subpostmaster i think between the 31st of march 1998 and the 5th of november 2003.— 31st of march 1998 and the 5th of november2003. yes. so 31st of march 1998 and the 5th of november 2003. yes. so a period of five and a half _ november 2003. yes. so a period of five and a half years or so. that's - five and a half years or so. that's correct. five and a half years or so. that's correct- by _ five and a half years or so. that's correct. by comparison, - five and a half years or so. that's correct. by comparison, if- five and a half years or so. that's correct. by comparison, if you i five and a half years or so. that's i correct. by comparison, if you don't mind me saying _ correct. by comparison, if you don't mind me saying to _ correct. by comparison, if you don't mind me saying to other— mind me saying to other subpostmasters, that's a relatively short period. it subpostmasters, that's a relatively short period-— short period. it is. it is, but it is due to _ short period. it is. it is, but it is due to the _ short period. it is. it is, but it is due to the post _ short period. it is. it is, but it is due to the post office i short period. it is. it is, but it is due to the post office and l short period. it is. it is, but it. is due to the post office and not myself — is due to the post office and not m self. ,, �* , myself. quite. and i suppose ironically _ myself. quite. and i suppose ironically you _ myself. quite. and i suppose ironically you spent _ myself. quite. and i suppose ironically you spent more i myself. quite. and i suppose| ironically you spent more than myself. quite. and i suppose i ironically you spent more than four times that period campaigning. filth. times that period campaigning. 0h, es. and times that period campaigning. oh, yes- and why _ times that period campaigning. oh, yes- and why has — times that period campaigning. oh, yes. and why has that _ times that period campaigning. oh, yes. and why has that be _ times that period campaigning. 0h, l

yes. and why has that be necessary? initiall it yes. and why has that be necessary? initially it was _ yes. and why has that be necessary? initially it was because _ yes. and why has that be necessary? initially it was because the _ yes. and why has that be necessary? initially it was because the post i initially it was because the post office _ initially it was because the post office terminated my contract, gave me three _ office terminated my contract, gave me three months' notice, and not giving _ me three months' notice, and not giving me — me three months' notice, and not giving me a — me three months' notice, and not giving me a reason for doing so. purety— giving me a reason for doing so. purely because in my belief it was because _ purely because in my belief it was because i— purely because in my belief it was because i kept raising problems and concerns— because i kept raising problems and concerns over its horizon system due to a number— concerns over its horizon system due to a number of faults i had found over— to a number of faults i had found over the — to a number of faults i had found over the years.— to a number of faults i had found over the years. you tell us in your statement — over the years. you tell us in your statement that _ over the years. you tell us in your statement that you _ over the years. you tell us in your statement that you spent - over the years. you tell us in your statement that you spent that i over the years. you tell us in your. statement that you spent that period of time seeking justice, accountability and redress for not just yourself and your wife, but also on behalf of a much wider group of people, is that right? yes. also on behalf of a much wider group of people, is that right?— of people, is that right? yes, i did. of people, is that right? yes, i did- once _ of people, is that right? yes, i did. once i'd — of people, is that right? yes, i did. once i'd started _ of people, is that right? yes, i did. once i'd started my- of people, is that right? yes, i i did. once i'd started my individual little _ did. once i'd started my individual little campaign we've found others along _ little campaign we've found others along the — little campaign we've found others along the way and eventually we all

joined _ along the way and eventually we all joined up _ along the way and eventually we all joined up andesa along the way and eventually we all joined up and jfsa was born and onwards— joined up and jfsa was born and onwards went the campaign. you sa in: onwards went the campaign. you saying your _ onwards went the campaign. gm. saying your witness statement you have dedicated this part of your life this cause. is that how it has seemed felt? firstly that it has required dedication, but secondly it is a cause? i required dedication, but secondly it is a cause? ~ , required dedication, but secondly it isacause? ~ , ., is a cause? i think it is also stubbornness _ is a cause? i think it is also stubbornness as _ is a cause? i think it is also stubbornness as well. i is a cause? i think it is also stubbornness as well. as i is a cause? i think it is also i stubbornness as well. as you got is a cause? i think it is also - stubbornness as well. as you got to meet _ stubbornness as well. as you got to meet people and realised it wasn't 'ust meet people and realised it wasn't just yourself and you saw the harm and injustice that had been descended upon them, it was something you felt you had to deal with _ something you felt you had to deal with it's _ something you felt you had to deal with. it's something you couldn't put down — with. it's something you couldn't put down. and you had the support of the rest _ put down. and you had the support of the rest of— put down. and you had the support of the rest of the group in there as welt _ the rest of the group in there as well. 00— the rest of the group in there as well. . ~ the rest of the group in there as well. ., ,, ., ., ., . .,

well. do take a moment to clear the fro in well. do take a moment to clear the frog in your — well. do take a moment to clear the frog in your throat. _ well. do take a moment to clear the frog in your throat. hopefully - well. do take a moment to clear the frog in your throat. hopefully not i well. do take a moment to clear the frog in your throat. hopefully not a l frog in your throat. hopefully not a welsh one! — frog in your throat. hopefully not a welsh one! talking _ frog in your throat. hopefully not a welsh one! talking of— frog in your throat. hopefully not a welsh one! talking of which, i frog in your throat. hopefully not a welsh one! talking of which, you i frog in your throat. hopefully not a i welsh one! talking of which, you ran a ost welsh one! talking of which, you ran a post office — welsh one! talking of which, you ran a post office in _ welsh one! talking of which, you ran a post office in north _ welsh one! talking of which, you ran a post office in north wales. - welsh one! talking of which, you ran a post office in north wales. i- welsh one! talking of which, you ran a post office in north wales. i did. i a post office in north wales. i did. what was the _ a post office in north wales. i did. what was the name _ a post office in north wales. i did. what was the name of _ a post office in north wales. i did. what was the name of the - a post office in north wales. i did. what was the name of the post i what was the name of the post office? it what was the name of the post office? . , ., ., what was the name of the post i office?_ what office? it was in llandudno. what kind of post _ office? it was in llandudno. what kind of post office _ office? it was in llandudno. what kind of post office was _ office? it was in llandudno. what kind of post office was it? - office? it was in llandudno. what kind of post office was it? it i office? it was in llandudno. what kind of post office was it? it was | office? it was in llandudno. what| kind of post office was it? it was a three position _ kind of post office was it? it was a three position counter. _ kind of post office was it? it was a three position counter. when i kind of post office was it? it was a three position counter. when we i three position counter. when we first bought the property was very much _ first bought the property was very much at _ first bought the property was very much at the back of the property and was a _ much at the back of the property and was a bit _ much at the back of the property and was a bit run — much at the back of the property and was a bit run down. it also had a retail— was a bit run down. it also had a retail side — was a bit run down. it also had a retail side to the business which was a _ retail side to the business which was a whole variety of things, crafts, — was a whole variety of things, crafts, knitting, haberdashery. it was a _ crafts, knitting, haberdashery. it was a whole range of things. for the first year—

was a whole range of things. for the first year or — was a whole range of things. for the first year or two we just ran the business — first year or two we just ran the business as— first year or two we just ran the business as it was and slowly developed from there putting on a bil developed from there putting on a big extension, updating a lot of the stock _ big extension, updating a lot of the stock but— big extension, updating a lot of the stock. but more importantly we actually— stock. but more importantly we actually saw it as a big potential to grow— actually saw it as a big potential to grow the post office business. we brought— to grow the post office business. we brought it _ to grow the post office business. we brought it right to the front of the building _ brought it right to the front of the building with a large queueing area for people, unfortunately it seems it's what— for people, unfortunately it seems it's what post office is needed. we invested _ it's what post office is needed. we invested quite heavily in developing the post— invested quite heavily in developing the post office and that was at the time the _ the post office and that was at the time the horizon system came in. | time the horizon system came in. i think time the horizon system came in. think you time the horizon system came in. i think you and your wife were 44 years old when you took it over. about that, yes, it would have been. you say _ about that, yes, it would have been. you say in _ about that, yes, it would have been. you say in a — about that, yes, it would have been. you say in a witness statement, in summary terms about your decision to become a subpostmaster, your decision to pick this post office,

your hopes and aspirations and the process by which you applied and by which your application was approved, ijust want to which your application was approved, i just want to look at an account you have given in the past in more detail about that. can we look please on the screen. this is a witness statement you made in the course of the group litigation proceedings in the high court and we will deal more about that later today. court and we will deal more about that latertoday. is court and we will deal more about that later today. is that right? yes, it is.— that later today. is that right? yes, it is. ~ , ., yes, it is. we can see the date in the top right. _ yes, it is. we can see the date in the top right, the _ yes, it is. we can see the date in the top right, the 9th _ yes, it is. we can see the date in the top right, the 9th of - yes, it is. we can see the date in the top right, the 9th of august i the top right, the 9th of august 2018. this witness statement was made for the purposes of what came to be known as the common issues trial, is that right?— trial, is that right? that's correct- _ trial, is that right? that's correct. the _ trial, is that right? that's

correct. the the - trial, is that right? that's correct. the the process i trial, is that right? that's i correct. the the process by trial, is that right? that's - correct. the the process by which ou correct. the the process by which you applied _ correct. the the process by which you applied to — correct. the the process by which you applied to become _ correct. the the process by which you applied to become a - you applied to become a subpostmaster, the documents that were, or in fact were not given to you, were important issues and addressed in this witness statement in very great detail, is that right? that is right. in very great detail, is that right? that is right-— that is right. looking at page three, that is right. looking at page three. and — that is right. looking at page three, and picking _ that is right. looking at page three, and picking up - that is right. looking at page three, and picking up at i that is right. looking at page i three, and picking up at paragraph 11. you say a key attraction to working with post office would that it would provide secure employment based upon the fact it provides a community service and has an established brand in the community from among the various small business options available, a post office branch would in my mind be a safe option. i was also encouraged by the fact i could run a secondary business such as a retail shop alongside the post office branch. that sets out in summary your reasons for picking post office is a

future enterprise with your wife, is that right? future enterprise with your wife, is that riuht? . �* , future enterprise with your wife, is that riuht? . �*, .., . that right? that's correct. paragraph _ that right? that's correct. paragraph 12 _ that right? that's correct. paragraph 12 on _ that right? that's correct. paragraph 12 on this i that right? that's correct. | paragraph 12 on this page, that right? that's correct. i paragraph 12 on this page, right through to paragraph 23 on page five addresses the initial inquiries you made with the existing, or outgoing subpostmaster, peter savage, ithink his name was. subpostmaster, peter savage, ithink his name was-— subpostmaster, peter savage, ithink his name was._ and i his name was. that's correct. and the planned _ his name was. that's correct. and the planned visits _ his name was. that's correct. and the planned visits you _ his name was. that's correct. and the planned visits you made, i his name was. that's correct. and the planned visits you made, and| the planned visits you made, and indeed some unannounced visits you made to the post office in question as part of your due diligence, is that right?— as part of your due diligence, is i that right?_ looking that right? that's correct. looking at paragraph _ that right? that's correct. looking at paragraph 21 — that right? that's correct. looking at paragraph 21 on _ that right? that's correct. looking at paragraph 21 on page _ that right? that's correct. looking at paragraph 21 on page five. i you say you do remember that during one of your visits to the branch, mr savage explained he had a practice

of keeping unders sound over in the safe is a system to deal with any odd shorts or overs. i remember this because i thought it to be rather casual and unusual for a business. nevertheless i was not particularly concerned and considered it a matter for mr savage and his staff and i didn't understand it to involve large figures or to be that problematic. is that right? that is riaht, problematic. is that right? that is riuht, it problematic. is that right? that is right. it was _ problematic. is that right? that is right. it was very _ problematic. is that right? that is right, it was very odd _ problematic. is that right? that is right, it was very odd and - problematic. is that right? that is right, it was very odd and very i right, it was very odd and very strange — right, it was very odd and very strange i_ right, it was very odd and very strange, i thought, right, it was very odd and very strange, ithought, fora right, it was very odd and very strange, i thought, for a cash -based — strange, i thought, for a cash —based system, where you didn't actually— —based system, where you didn't actually record anywhere the amounts, and you didn't provide post office _ amounts, and you didn't provide post office returns on the position each week _ office returns on the position each week but — office returns on the position each week. but that seemed to be the way it operated _ week. but that seemed to be the way it operated. but week. but that seemed to be the way it o erated. �* , , ., it operated. but they were small sums of money. _ it operated. but they were small sums of money. they _ it operated. but they were small sums of money. they were i it operated. but they were small| sums of money. they were small it operated. but they were small - sums of money. they were small sums of mone , sums of money. they were small sums of money. yes- — sums of money. they were small sums of money, yes. from _ sums of money. they were small sums of money, yes. from paragraph - sums of money. they were small sums of money, yes. from paragraph 24, - sums of money. they were small sums of money, yes. from paragraph 24, if. of money, yes. from paragraph 24, if we scroll down, _ of money, yes. from paragraph 24, if we scroll down, please. _ of money, yes. from paragraph 24, if we scroll down, please. right - we scroll down, please. right through to paragraph 33 at the bottom of page seven, you deal with

the agreement to purchase the post office. , the agreement to purchase the post office. yes. moving forward to page eiaht. from paragraph 34 on this page right through to paragraph 86 on page 19, you deal with the following issues. i would just summarise them without reading the text. firstly, the application to the post office to be application to the post office to be a subpostmaster. secondly, the interview at the regional office that you and your wife attended in bangor. thirdly the confirmation that your application had been successful and the material you were then given, yes? successful and the material you were then given. yes?— successful and the material you were then given, yes?- if— successful and the material you were then given, yes?- if you - successful and the material you were then given, yes? yeah. if you can go forward to page _ then given, yes? yeah. if you can go forward to page 15. _ looking at paragraph 62, you say, at

no stage during the process of my application, appointment and branch opening was i ever sent her copy of the subpostmaster contract. i first obtained a copy of the subpostmaster contract much later in circumstances i explain below. at no point during my appointment process was it mentioned or explained to me that the subpostmaster contract, which was a lengthy document of 114 pages, govern the terms of my appointment. we will hear later, is this right, that the post office robustly challenged you on that issue alongside other issues at the trial and then the trialjudge then, mr justice fraser, held that you were an honest witness, that you were telling the truth, and that like many other subpostmasters you did not receive a copy of this document? that's correct. you not receive a copy of this document? that's correct-— that's correct. you address later in this section — that's correct. you address later in this section of _ that's correct. you address later in this section of your _ that's correct. you address later in

this section of your witness - this section of your witness statement, your initial classroom training and then lastly the transfer of the branch to you and the opening of it, correct? correct, es. can the opening of it, correct? correct, yes- can we — the opening of it, correct? correct, yes- can we turn — the opening of it, correct? correct, yes. can we turn to _ the opening of it, correct? correct, yes. can we turn to the _ the opening of it, correct? correct, | yes. can we turn to the introduction ofthe yes. can we turn to the introduction of the horizon _ yes. can we turn to the introduction of the horizon system _ yes. can we turn to the introduction of the horizon system into - yes. can we turn to the introduction of the horizon system into your - of the horizon system into your branch and can we go to your inquiry witness statement, please. at page five. paragraph 14. you tell us that in october 2000, the post office introduced horizon at my branch...

horizon installed under two years after you took up the position of subpostmaster of this office. correct. ., ., ., ' subpostmaster of this office. correct. ., ., ., correct. scroll down to 15. you sa paragraph 16, please. you say...

you have told us in summary that you regarded it as a positive innovation. going back to what you say on the previous page, you say in the third line, i didn't expect there to be any apparent discrepancies shown on the system that you were unable to identify the cause of and resolve. what do you mean by that? ihell.

identify the cause of and resolve. what do you mean by that? well, i exected what do you mean by that? well, i exoeeted to _ what do you mean by that? well, i exoeeted to be _ what do you mean by that? well, i expected to be able _ what do you mean by that? well, i expected to be able to _ what do you mean by that? well, i expected to be able to track- what do you mean by that? well, i expected to be able to track down | expected to be able to track down any transaction that i'd undertaken myself. _ any transaction that i'd undertaken myself. or— any transaction that i'd undertaken myself, or my staff had undertaken, at the _ myself, or my staff had undertaken, at the branch. one way or another, there _ at the branch. one way or another, there are _ at the branch. one way or another, there are a — at the branch. one way or another, there are a variety of ways of interrogating systems and the data on the _ interrogating systems and the data on the systems. i presumed the system — on the systems. i presumed the system would enable you to do that at the _ system would enable you to do that at the outset. in previous roles, before _ at the outset. in previous roles, before post office, i had used something like crystal reports on software — something like crystal reports on software packages to extract information using certain parameters. but there was very little — parameters. but there was very little flexibility and horizon as i saw it _ little flexibility and horizon as i saw it at — little flexibility and horizon as i saw it at that time for reports that you could —

saw it at that time for reports that you could control the parameters of your searches for. there were a set of reports. — your searches for. there were a set of reports, don't get me wrong, there _ of reports, don't get me wrong, there were _ of reports, don't get me wrong, there were a set already built into there were a set already built into the system, but they were quite restrictive — the system, but they were quite restrictive in there. it did seem to cause _ restrictive in there. it did seem to cause problems. we restrictive in there. it did seem to cause problems.— cause problems. we see this as a feature in — cause problems. we see this as a feature in the _ cause problems. we see this as a feature in the correspondence - cause problems. we see this as a | feature in the correspondence that we will turn to a little later today, and a constant theme that you pursued. that is to say, the visibility of transactions and the audit ability of transactions from a subpostmasters' perspective was lacking in the horizon system, was that correct?— lacking in the horizon system, was i that correct?_ can that correct? very much so, yes. can return back — that correct? very much so, yes. can return back to _ that correct? very much so, yes. can return back to your _ that correct? very much so, yes. can return back to your high _ that correct? very much so, yes. can return back to your high court - return back to your high court statement. and turn to page 32, please.

and can we pick it up at paragraph 144. you say that you have been referred to a part of the post office's defence... and this is what the post office said, it would not be right to infer or presume that a shortfall in loss was caused instead by a bug or error in horizon. and that the truth of whether a shortfall did or did not

result from losses for which the subpostmaster was responsible, lies peculiarly within the knowledge of subpostmasters, is the person with the responsibility for branch operation and the conduct of transactions in branches. you say these things were in my own experience very far from the case. and then you set out from your own experience by comparison what you say by reference to what the post office suggest. can we look at paragraph 145, please? you say, i didn't expect there to be any apparent shortfall is that you were unable to identify. that's essentially what you said in your inquiry witness statement. and then 146, you say, one of my fundamental

concerns when horizon was introduced, which you have clearly communicated through various letters, was the lack of transparency and control available to me in reviewing transactions when trying to balance. you refer to a letter and you say, i could not fully access data that i needed in order to properly track and if necessary to correct transactions. your concerns came to a head in december 2000 following a particularly difficult balance. you would therefore dependent, you say, on the post office for this sort of information and therefore in order to ascertain the cause of any apparent shortfall and whether it was in fact a real loss. and then you say in 147, although post office later moved to monthly balance and, during your tenure you were required to produce weekly accounts meaning you had to conduct a balance on a weekly basis on a wednesday. when

carrying out this balance on wednesday the 13th of december 2000 at the horizon system showed there was an unexplained variance of more than £6,000 relating to giro deposits. the first substantial unexplained variance was over £6,000, is that right mr blue yes. and it was only a number of weeks after the system had gone live. i was going to ask about the system live on the 2nd of october and we are now talking about the 13th of december, so around two months or so after the system had been installed, these variance arose. yes. . if we can no these variance arose. yes. . if we can go back _ these variance arose. yes. . if we can go back to — these variance arose. yes. . if we can go back to paragraph 148.

over the page, please. thank you. you say, as you mentioned in a paragraph above, i contacted the helpline, seeking support and help as to why this apparent variance had occurred. they were unable to assist in any meaningful way. i tried to investigate the matter myself, printing various reports from two of my three counter terminals. i left the third terminalfor my three counter terminals. i left the third terminal for use to serve customers as we were very busy in the branch with customers queueing out of the door. you cross refer back to paragraph 143.1. i don't want to go there but essentially you tell us in a paragraph that on that day, the 13th of december 2000, you contacted the helpline seven times, is that right?_ one . is that right? that's correct. one ofthe is that right? that's correct. one of the calls _ is that right? that's correct. one of the calls was _ is that right? that's correct. one of the calls was around - is that right? that's correct. one of the calls was around one - is that right? that's correct. one of the calls was around one hour| is that right? that's correct. one l of the calls was around one hour in length. of the calls was around one hour in

lenath. .. of the calls was around one hour in length- were _ of the calls was around one hour in length.- were they _ of the calls was around one hour in length.- were they in - of the calls was around one hour in length.- were they in any - length. yeah. were they in any assistance _ length. yeah. were they in any assistance in _ length. yeah. were they in any assistance in the _ length. yeah. were they in any assistance in the course - length. yeah. were they in any assistance in the course of - length. yeah. were they in any i assistance in the course of those seven calls?— assistance in the course of those seven calls? ., ., , ,, ., seven calls? not really. stating the bleedin: seven calls? not really. stating the bleeding obvious, _ seven calls? not really. stating the bleeding obvious, i _ seven calls? not really. stating the bleeding obvious, i think, - seven calls? not really. stating the bleeding obvious, i think, really, i bleeding obvious, ithink, really, is one _ bleeding obvious, ithink, really, is one description i might use. all things— is one description i might use. all things aside, it was tried. did they sur est things aside, it was tried. did they suggest anything? _ things aside, it was tried. did they suggest anything? no. _ things aside, it was tried. did they suggest anything? no. the - things aside, it was tried. did they suggest anything? no. the other i suggest anything? no. the other impression _ suggest anything? no. the other impression i _ suggest anything? no. the other impression i got _ suggest anything? no. the other impression i got was _ suggest anything? no. the other impression i got was that - suggest anything? no. the other impression i got was that they i impression i got was that they couldn't— impression i got was that they couldn't access the system any further— couldn't access the system any further than i could at the time. by further than i could at the time. bw way of further than i could at the time. way of an further than i could at the time. by way of an aside, i think you tell us in your statement that post office records subsequently disclosed to you show that in the two year and nine—month period up until november 2003, that is to say when your contract was terminated, you and your assistance made 507 calls to the helpline of.— your assistance made 507 calls to the helpline of.- of - your assistance made 507 calls to the helpline of.- of which | the helpline of. correct. of which

85 related to _ the helpline of. correct. of which 85 related to horizon _ the helpline of. correct. of which 85 related to horizon and - the helpline of. correct. of which l 85 related to horizon and balancing problems. and you found the helpline to be ineffective and indeed of no help. to be ineffective and indeed of no hel. , . ,., ., to be ineffective and indeed of no hel. , . ., ., help. very much so, and often we never bothered _ help. very much so, and often we never bothered ringing _ help. very much so, and often we never bothered ringing it. - you see, using the limited reports you are able to print you see, using the limited reports you are able to print you ascertained that around £5,000 of the alleged shortfall relating to gyro items that had become wrongly duplicated on horizon, these reports were in the form of lengthy narrow line till receipts many metres long, making them difficult to review in any event. at the time i believe that a majority of the remaining alleged shortfall, £1182, was also attributable to errors, however i was not able to track is potentially smaller sums in the absence of proper reporting functions on

horizon. therefore, farfrom being within my knowledge, i was unable to ascertain the root cause of the apparent shortfall at all. you have your thoughts, which are set out later. i called my retail network manager the following day to inform him. in the absence of a proper response from the post office i carried out, i carried over the apparent shortfall from that weak�*s cash account to the following week's cash account to the following week's cash account to the following week's cash account by transferring it to a suspense account, which was visible to the post office. £5,000 of that £6,000 was attributable to wrongly duplicated giros. the remaining £1100, is it that that you end up in dispute with the post office over?

at the time, yes. you wrote