That is, that people that employees that are further down the chain have not – escalated it or reported the issues all the way up the chain?Yes, I think that’s correct. And does that mean reported up to the GLT?It could mean that, yes. And then the seventh point is: An inadequate control environment. What does that mean?Again, if we go to that discussion this morning, I think I mentioned six issues that drive the way in which the business operates, controls being the critical one, and I think we acknowledge that the control environment wasn’t as strong as it should have been. And then point (a) is: Insufficiently clear policy/guidance in relation to the requirements for switching off ongoing service fees And paragraph 165 seems to provide an explanation of what that’s said to mean which is that: An aspect of the insufficiency of clear policy and guidance was the business practice which developed whereby exceptions to the BOLR policy were granted to allow ongoing service fees to remain on when customers were transferred into the BOLR pool. This business practice is known as the 90 day exception I just want to understand what it is you are saying here in your evidence in these paragraphs. Why is the fact of a business rule an example of insufficiently clear policy or guidance?I believe that refers to the fact that the document the BOLR – policy wasn’t explicit in that regard. Didn’t explicitly say what, that you should leave fees on for 90 days or that you shouldn’t leave fees on at all?That’s correct. No, no?The latter. The latter. Does as you understand it, to any extent does the Group Leadership – Team take responsibility for any of the failures in relation to BOLR?Yes. If you go to paragraph 225 of your statement, which is on page 44, you note that: It appears that no GLT member received any of the internal legal advices. And you say:
That is, that people – that employees that are further down the chain have not escalated it or reported the issues all the way up the chain?Yes, I think that’s correct. And does that mean reported up to the GLT?It could mean that, yes. And then the seventh point is: An inadequate control environment. What does that mean?Again, if we go to that discussion this morning, I think I mentioned six issues that drive the way in which the business operates, controls being the critical one, and I think we acknowledge that the control environment wasn’t as strong as it should have been. And then point (a) is: Insufficiently clear policy/guidance in relation to the requirements for switching off ongoing service fees And paragraph 165 seems to provide an explanation of what that’s said to mean which is that: An aspect of the insufficiency of clear policy and guidance was the business practice which developed whereby exceptions to the BOLR policy were granted to allow ongoing service fees to remain on when customers were transferred into the BOLR pool. This business practice is known as the 90 day exception I just want to understand what it is you are saying here in your evidence in these paragraphs. Why is the fact of a business rule an example of insufficiently clear policy or guidance?I believe that refers to the fact that the document – the BOLR policy wasn’t explicit in that regard. Didn’t explicitly say what, that you should leave fees on for 90 days or that you shouldn’t leave fees on at all?That’s correct. No, no?The latter. The latter. Does – as you understand it, to any extent does the Group Leadership Team take responsibility for any of the failures in relation to BOLR?Yes. If you go to paragraph 225 of your statement, which is on page 44, you note that: It appears that no GLT member received any of the internal legal advices. And you say:
transcript-17-april-2018.docx