Filed on behalf of the: Defendant

Witness: T. Mather
Statement No.: First
Date Made: 16 November 2018

Claim No: HQ16X01238, HQ17X02637 & HQ17X04248

THE POST OFFICE GROUP LITIGATION

IN THE HIGH COURT OF JUSTICE
QUEEN'S BENCH DIVISION
ROYAL COURTS OF JUSTICE

BETWEEN:

ALAN BATES & OTHERS

Claimant

AND

POST OFFICE LIMITED

Defendant

WITNESS STATEMENT OF TRACY JANE WENDY MATHER

I, TRACY JANE WENDY MATHER of No 1 Future Walk, West Bars, Chesterfield,

Derbyshire S49 1PF WILL SAY as follows:

1. I am employed by Post Office Limited (Post Office) as the Finance Service

Centre (FSC) Team Leader and I make this statement on Post Office's behalf.

2. References to paragraph numbers are to paragraphs in Jason Coyne's IT expert

report.

3. The facts set out in this statement are within my own knowledge, or if they are
outside my knowledge, I have explained the source of my information or belief.

BACKGROUND

4. I started working for Post Office on 26 January 1987 and have been in FSC since
I began my employment. I became a team leader in 1999. The teams I have
managed are the Cheque team, Postal Order, Pay-out and MoneyGram.

5. When I began working at Post Office everything was paper-based. I saw first
hand the introduction of Horizon and t.he processes put in place in relation to it.

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EXPERT REPORT OF JASON COYNE

6. I have been shown paragraphs 5.174, 5.175 and 5.176 of an IT expert report by {D2/1/101}; {D2/1/102}
Mr Jason Coyne.

7. At paragraph 5.174 Mr Coyne refers to an extract from a joint Post Office and {D2/1/101}
Fujitsu document entitled "End to End Reconciliation Reporting" and quotes the
following: "There is no formal reconciliation produced between the POLSAP
System and the Credence transaction stream. The Credence stream should
therefore not be used to verify financial integrity and Post Office should ensure
the POLSAP System Transaction information is used for this purpose". Mr Coyne
goes on to refer to the Helen Rose report {POL-0221677} and the reference to
Post Office examining Credence data in relation to a transaction that took place at
Lepton SPSO. He questions why Post Office were using Credence to initially
investigate disputed transactions.

8. In this statement I will explain the extent to which Post Office has used Credence
to investigate discrepancies since the introduction of Horizon and why.

CREDENCE

9. Credence is a system that shows all sales transactions, log on and log off events
and all remittances in and out of Horizon. Credence gets its information from
Horizon and when I am looking for information from Credence, I will download the
information I am looking for into the format of an excel spread sheet. Credence
should be distinguished from POLSAP, which is Post Office's back end
accounting system. I can get view information on POLSAP, for example a
summary of cheques remmed out and the relevant branch dates, whereas on
Credence I have to locate the information myself and either view on screen or
download it. POLSAP is used at a higher level, whereas Credence can give us
the individual detail of each transaction.

10. I understand from our Management Information specialists that Credence was
adopted by FSC in April/May 2009. It is used in my team to investigate hundreds
of open items created in the POLSAP system due to differences between what a
branch says has happened to a transaction through Horizon and what a different
source of information might say. For example, cheques taken as a method of
payment which are settled in branch must match the physical cheques sent for
processing each day. Intelligent Processing Solutions Limited (IPSL) who
process the cheques create a file which is loaded into POLSAP. Any differences
between the information in that file and the information from the branch on
Horizon will be investigated by my team using Credence.

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 Claim No: HQ16X01238, HQ17X02637 & HQ17X04248

11. It is correct that there is no formal reconciliation between POLSAP and Credence.
POLSAP is the main accounting system that Post Office use to verify financial
information. All discrepancies (we tend to refer to them as errors) are
investigated to see the source of the error. The investigation may result in a
Transaction Correction being issued to a branch. For example, if a branch
entered a transaction as a cash payment transaction when in fact it was a cheque
payment transaction, the branch would be short in its cash. In this instance, the
matter would be investigated and it would be seen that the branch's cheques are
overstated by the relevant amount. Post Office would therefore issue the branch
with a Transaction Correction as a credit to cover the shortage in its cash.

12. Credence is used as an information tool. It is designed to work alongside other

applications. It is used to help understand what has happened in a branch as it
records all key stroke activity performed in that branch by the user ID, date and
time. Post Office cannot issue nor amend anything on Credence.

13. Post Office can use Credence to investigate discrepancies but it does so as a
"back up" tool to understand/investigate what a Subpostmaster says happened in
a branch. For example, a Subpostmaster might telephone FSC and/or the
helpline and allege to Post Office that he/she has done a reversal. We can take
an initial look on Credence to see whether that is correct or whether, for example,
the Subpostmaster has in fact done an adjustment. By using Credence, we can
identify when this happened and provide a session ID to the Subpostmaster. The
Subpostmaster can input the session ID into Horizon and verify it themselves
within a certain number of days from the date of the transaction. After that period
of time, the Subpostmaster can use their own paperwork kept in branch to clarify
what has happened. I should point out that Credence is not only used to
investigate discrepancies: I understand that it is also used by Product Managers
for sales, for example.

14. In relation to Mr Coyne querying whether Credence could contain errors that
result in false TCs being issued to branches which they cannot effectively
challenge, as I am an end-user of Credence I cannot really comment on this.
However I have never heard of a bug in Credence in my time at Post Office.

15. Looking at the Helen Rose report referred to in paragraph 5.49 of Mr Coyne's {D2/1/67}
report, Post Office was able to use Credence to identify that the Subpostmaster
had reversed a transaction but had also taken £76.09 payment from the
customer. In reversing the transaction, the Subpostmaster had effectively
removed the payment to British Telecomm, making the bill unpaid.

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 Claim No: HQ16X01238, HQ17X02637 & HQ17X04248

16. Normally when a bill is paid it is done through Horizon, i.e. Horizon will send the
payment onto British Telecom. Where the payment is not made, the customer
would get a red reminder from British Telecom to say that they had not paid their
telephone bill. Such a customer would then either contact Post Office, go into a
branch or contact British Telecom to explain that they had paid the bill, provide a
copy of their receipt and question why British Telecom had not received their
payment. Credence is used as a tool to investigate what happened in the branch
regarding the customer payment. Whether the reversal was manual or a
technical issue, the branch had taken the payment for a bill payment where the
bill was not paid but the branch still had the money. Post Office was correct to
"claim" that money from the branch via a debit Transaction Correction and pay the
customer bill directly through its Automated Payment team.

17. Post Office has other tools available to it to investigate discrepancies, it is not
limited to electronic-based applications. Subpostmasters have to make
declarations relating to cheques and cash, for example, and Post Office can use
these as part of their investigations. In relation to the allegation that when
shortfalls are queried, Post Office assumes the Subpostmaster is to blame, whilst
I can't answer for everyone, I find this allegation surprising because before any
Transaction Correction is issued, Post Office investigates the matter.

ARQ REQUESTS

18. I understand that Mr Coyne has alleged that Post Office staff were deterred from
making ARQ requests because of fees or penalties.

19. I understand that a witness statement of Fujitsu's Torstein Olav Godeseth

contains details of the number of ARQs issued since the 2014/15 financial year. I
have spoken to my colleague Christopher Knight, the Intel & Admin Team Leader,
who has confirmed that Post Office get an allowance of 720 data queries a year
(roughly 60 a month). He is not aware of any fees or penalties having been paid
by Post Office, nor anyone being deterred from making ARQ requests because of
fees that might have to be paid by Post Office.

20. I understand that Fujitsu have confirmed to Post Office's solicitors that Post Office
have only exceeded their contractual limit when extra data was required as part of
this litigation and that a new commercial term was issued in this instance detailing
what was agreed and how much it would cost. Any requests above the agreed
amount are chargeable but I understand that the terms depend on the details of
the requirement.

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 Claim No: HQ16X01238, HQ17X02637 & HQ17X04248

STATEMENT OF TRUTH

I believe that the facts stated in this witness statement are true.
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Date:
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