Opening Statements - Tranche 3 Phase 1 Participant Positions

Full transcript

00:20:06 Good morning everybody. This is the second of three days of oral openings. Uh I will invite uh Miss Secand Kings Council to uh address us first.

00:20:35 Mr. Gant, good morning. Good morning, sir. I was waiting for my mic to be switched on. Yeah. Yes. The technology is baffling, but um I'm glad that that other people find it as baffling as I do. Please.

00:20:53 find it as baffling as I do. Please. We all do, sir. Well, sir, I make this opening on behalf of Peter Francis, the former special demonstration squad officer who later became a whistleblower. Sir this opening was written and is being delivered before we have received full trans disclosure and particular uh in particular we do not as yet have

00:21:04 in particular we do not as yet have HN86's statement. I I know you will bear that in mind. Additionally given that we only received other core participants openings on Friday in the late

00:21:15 openings on Friday in the late afternoon. Our opening is not as responsive as I would have liked it to be.

00:21:21 be. It is almost exactly five years since we wrote and delivered an opening on behalf of Peter Francis in Tranch One phase one of this inquiry.

00:21:35 of this inquiry. Time has most certainly not um flown by for him since then. What this whole experience has taught him is that nobody really likes a whistleblower. Although whistleblowers are traditionally heroes to some and

00:21:50 traditionally heroes to some and traitorous villains to others, here in this inquiry, Mr. Francis faces criticism from every corner, the police, the spied upon, and no doubt in due

00:22:01 the spied upon, and no doubt in due course the inquiry itself through its council.

00:22:02 council. It's however important for us to point out, sir, that whether you wish to hear it or not, that no one within the inquiry machinery has acknowledged his trauma. he his known psychiatric

00:22:15 trauma. he his known psychiatric conditions and no one has thanked him for his courage in speaking out. No one has apologized to him for the extraordinary delay in bringing this

00:22:27 extraordinary delay in bringing this phase to the public either through his lawyers or directly. So if he was once a hero to somebody, the problems that have beset this inquiry and the consequent glacial pace with which it has proceeded have just

00:22:39 with which it has proceeded have just made him a a an inconvenient truth to many. So this can be seen from two of the openings in particular, those from the designated lawyers group and from those uh upon whom he spied.

00:22:54 those uh upon whom he spied. Mr. Francis cannot apologize for telling the truth. He cannot apologize on behalf of the SDS. That is not in his gift. But he can and will apologize for the hurt

00:23:10 he can and will apologize for the hurt and pain he has caused to those he spied upon. And he is also willing to take full personal responsibility despite the fact that he was doing his job and he was doing it as directed by his managers.

00:23:22 managers. Sir, he is especially remorseful about using the identity of a deceased child to create his cover story. A and to that

00:23:33 to create his cover story. A and to that family, he says, and I quote, "There are no words sufficient to describe the profound wrong I committed against you." Now, please know that the depth of my regret is absolute.

00:23:47 regret is absolute. His account is his truth and the truth. For those who like the designated lawyers group call him a liar or a fantasist, he responds by saying,

00:23:58 fantasist, he responds by saying, "Perhaps that is because my account does not suit your story, the one you have told yourself in order to live with your past." We remind you, sir, the words of the Ellison Review, and I quote, "We

00:24:12 the Ellison Review, and I quote, "We feel unable to reject his claims simply because other SDS officers deny them.

00:24:20 Mr. Francis has adopted the sentiment behind the words attributed to an American educator by the name of Charles

00:24:34 American educator by the name of Charles Seabour and repeated by the harbinger to Keani Reeves as John Wick who says we shall seek the truth and endure the consequences and he has certainly endured this great weight to speak his

00:24:47 endured this great weight to speak his truth with patience and tolerance out of respect for the inquiry process and his personal respect for you sir once the inquiry started Um he refrained from all further engagement

00:24:58 engagement uh with the media and has waited perhaps far too patiently to give his full account to the inquiry. He he has endured strange lies about him in the earlier tranches such as officers like Andy Cole saying he shot a wild boar

00:25:09 Andy Cole saying he shot a wild boar with a firearm in Germany and Trevor Morris suggesting to Operation Herm that Mr. Francis was twice admitted to a psychiatric hospital. He has endured the

00:25:22 psychiatric hospital. He has endured the exacerbation of his SDS call psychiatric illness due to the waiting. He has endured his witness statement being redacted and slashed and reduced and now he has to endure adverse criticism on

00:25:34 he has to endure adverse criticism on all fronts. To recap on that endurance test, it is now over 15 years since Mr. Francis provided his first whistleblowing disclosure to the

00:25:47 whistleblowing disclosure to the Guardian as officer A on the 14th of March 2010. This was 6 months before Mark Kennedy was exposed by those he spied upon on the 24th of October 2010. By 2011, the

00:26:00 the 24th of October 2010. By 2011, the media was publishing articles naming the source as Peter Black, Mr. Francis's special branch alias. In June 2020 uh in

00:26:11 special branch alias. In June 2020 uh in June 2013, he chose to unmask himself in a dispatch's documentary on police undercover practices which together with other disclosures he made at this time resulted in the broadening of the terms of reference of the Ellison review. It

00:26:26 of reference of the Ellison review. It was the publication of the findings of this re review together with Mr. Francis's whistleblowing efforts and certain revelations from activists that coalesed in the decision by the then

00:26:40 coalesed in the decision by the then Home Secretary Theresa May on the 6th of March 2014 to call for a statutory inquiry into undercover policing. It is now 10 years since this inquiry was formally opened by Lord Justice

00:26:52 was formally opened by Lord Justice Pitchford in Mr. Francis's words, and I quote, "Had I known that the public inquiry would take over 10 years to hear more evidence, I would never have called for an inquiry in the first place." Uh,

00:27:07 for an inquiry in the first place." Uh, let's unpack this statement. Firstly, to date, not only has the inquiry not acknowledged the specific and different stresses that being a whistleblower brings, it has also not asked Mr. Francis what he needs to give his best

00:27:23 Francis what he needs to give his best evidence, whether written or oral, other than being sent a generic witness information pack in August 2025. He did not just blow the whistle on the kinds of misconduct that it turns out are true. A and pausing there, sir, we note, as you have, the significant

00:27:42 note, as you have, the significant admissions of misconduct and impropriety and unacceptable decisionmaking made by Mr. Skeleton on behalf of the Metropolitan Police Service both last year and yesterday. Uh uh Mr. Francis did it despite the

00:27:54 Uh uh Mr. Francis did it despite the fear of prosecution under the Official Secrets Act 1989. Somewhat extraordinary extraordinarily this inquiry only published a vulnerable witness pro protocol in July 2025 for

00:28:08 witness pro protocol in July 2025 for the first time some two years after Mr. Francis provided his written evidence and after two tranches of evidence were completed. Somewhat late in the day, it acknowledges and I quote that giving

00:28:24 acknowledges and I quote that giving evidence can be a daunting task which may cause levels of stress. Secondly, a decade down the line in this inquiry,

00:28:33 inquiry, we are only now entering phase one of tranch three of the evidence. When the inquiry was first set up, it was estimated it would take three years to complete. Perhaps you would have been

00:28:45 complete. Perhaps you would have been less optimistic than Sir Christopher. But nonetheless, at the time, like many others, Mr. Francis thought three years was just too long. uh despite inviting

00:28:57 was just too long. uh despite inviting the inquiry in his 2020 opening a and in fact before then in meetings with you to take his written statement from him as soon as possible. It was not until the

00:29:14 soon as possible. It was not until the summer of 2023 that Mr. Francis's rule 9 request was issued with responses that demanded

00:29:16 demanded uh with responses demanded within a highly compressed time scale. Whilst we recognize the hercul herculian

00:29:27 recognize the hercul herculian nature of the task as it was described by Mr. bar yesterday. The delay has taken a significant toll on his on his already severe mental health issues caused by his undercover deployment,

00:29:41 caused by his undercover deployment, compounded by the weight of his role in this inquiry as the sole police whistleblower on which he well knows a great deal of expectation and contention turns.

00:30:00 turns. The protracted stress and uncertainty as to when he would give such evidence has caused him and his partner immense strain.

00:30:02 strain. This 10-year limbo to an extent has reinflicted the trauma he suffered and

00:30:13 reinflicted the trauma he suffered and followed uh during and following his SDS deployment where he was left feeling entirely unsupported and alone. It bears remembering to that

00:30:24 and alone. It bears remembering to that for much of this weight, the spectre of prosecution under the Official Secrets Act remained hanging over him until January 2023 when the MPS commissioner finally provided the requisite asurances. Notwithstanding this, Mr. Francis has

00:30:38 Notwithstanding this, Mr. Francis has stayed with this inquiry. Uh many have

00:30:50 stayed with this inquiry. Uh many have come and gone in this inquiry, but he is still here. But unlike other undercover officers who suffer with similar psychiatric conditions, he is going to give his evidence orally and in the full glare of the public and with dignity if

00:31:06 glare of the public and with dignity if he is shown the respect any witness in a public inquiry deserves. He has always wanted to give every part of his evidence in fully open conditions and without censorship.

00:31:17 and without censorship. Where there are redactions in his witness statement, that is not his choice. Multiple restriction order hearings have been held to which Mr. Francis was not permitted to attend,

00:31:33 Francis was not permitted to attend, only his lawyers, despite the redaction of his evidence being the subject matter.

00:31:42 Sir, you may remember that back in 2018, as part of the inquiry process, Mr. Francis confirmed he would not be seeking an any anonymity or restriction over his undercover identities. It was at this stage that he revealed his third and deepest cover name for the first

00:31:54 and deepest cover name for the first time, that of Peter Johnson, a a a name regrettably taken from a deceased child. This was the last and perhaps most

00:32:10 This was the last and perhaps most difficult of all his public revelations. He had not made this disclosure earlier out of respect for the family of the child. It is however indicative of Mr. Francis's approach to this inquiry and of his motivation for blowing the whistle in the first place.

00:32:22 whistle in the first place. He believes that the public has the right to know what is done on their behalf of the true inner workings of the SDS during its lifetime. However

00:32:34 SDS during its lifetime. However unpalatable this may be and however sharply this may rebound on him. I want to say something now about Cander. Uh you may remember Mrs. Francis's strongly voiced opposition

00:32:48 Francis's strongly voiced opposition to the restriction order process early in this inquiry. A process which led to the protection of the rail and all cover names of a large number of officers. And as matters still stand, both of his SDS

00:33:06 as matters still stand, both of his SDS line managers at the time, namely uh his DCI HN86

00:33:08 DCI HN86 and his DI HN67, have full anonymity. HN86, who uh we say tasked Mr. uh

00:33:19 HN86, who uh we say tasked Mr. uh Francis to gain intelligence on the Steven Lawrence campaign, benefits from that anonymity. Council for the designated lawyers team, Mr. Sanders, has much to say about

00:33:36 Mr. Sanders, has much to say about HN86's evidence in his written opening. And one of the quotes is is from paragraph 249. So clearly he has a lot more to say, but only in writing, it seems. Uh I pause here to note, sir, that Mr. Sanders's

00:33:53 here to note, sir, that Mr. Sanders's uh DL group calls Mr. Francis a liar and his accounts preposterous. One of Mr. S uh Mr. Francis's demonstrable lies says Mr. Sanders is

00:34:04 demonstrable lies says Mr. Sanders is that Mr. Francis mentions a commander black in July 1997 when Mr. Sanders says that there was in fact no commander black then we would

00:34:16 fact no commander black then we would say we would simply say to Mr. Sanders and his clients that that he needs to check the facts. Um a and look at what is said in the explanatory note accompanying the officer timeline. Uh

00:34:27 accompanying the officer timeline. Uh that um HN what is said there is that HM146 Black was OCU commander OP from April 1996 and was promoted in December 1998

00:34:40 and was promoted in December 1998 although he retained his role as OCU commander. It may explain why in fact the commendation given to Mr. Francis in

00:34:54 the commendation given to Mr. Francis in 1998 is signed off by Colin Black as OCU commander. In accusing my client of fiction, Mr. Sanders has in fact created his own. Back to the question of

00:35:07 his own. Back to the question of anonymity. Mr. Francis's subsequent DCI HN58 and DIHN53 who was centrally involved with his reintegration into special branch and the sign significant failures in his

00:35:18 the sign significant failures in his post deployment support have both had their real and cover names restricted. Everyone will know now that HN81, also known by his cover name, David

00:35:34 also known by his cover name, David Hagen, was given anonymity over his real name. Again, something Mr. Francis pushed hard against at the time at the time of your decision making, sir. Perhaps it is academic now that he's

00:35:48 Perhaps it is academic now that he's been given a full recusal by you, sir, despite his centrality about which we will say more later. Mr. Francis firmly believes that senior and significant individuals no longer even active in

00:35:59 individuals no longer even active in policing should not be permitted to hide behind a cloak of secrecy. He has always said that the restrictions of these officers identities sometimes on both

00:36:14 officers identities sometimes on both their cover and real names undermines the key tenets of accountability, openness and transparency which should underpin this inquiry.

00:36:34 underpin this inquiry. Peter Francis firmly believes that only when you come into the cold light of day, unmasked, can you be truly accountable. In our view, the police approach to this inquiry to date does not sit well with the government's commitment to the duty of cander recently enshrined in the

00:36:45 of cander recently enshrined in the public account office accountability bill, also known as the Hillsborough Law. The bill, which is still wending its way through the parliamentary

00:36:57 its way through the parliamentary process, seeks to embed a statutory duty of Canada, requiring all state agencies and public officials to act with honesty

00:37:10 and public officials to act with honesty and frankness and in the public interest uh in the public interest generally and specifically in relation to court proceedings, official inquiries and investigations. The bill as currently formulated repeatedly uses the three words transparency, cander, and

00:37:28 words transparency, cander, and frankness when describing the duties of public servants, including in relation to assisting public inquiries in relation to their own activities. A failure to meet that duty will be a crime if the bill becomes law. The

00:37:40 crime if the bill becomes law. The government's just justification for the bill arises from some of the significant

00:37:54 bill arises from some of the significant failings following the Hillsbor disaster uh which includes and I quote police officers lying and changing witness statements to protect reputations. While of course the very nature of the type of undercover policing being examined by this inquiry involved an intentional misleading of the general

00:38:08 intentional misleading of the general public by the police, a crime under the new bill in other circumstances. The bill reflects the government's belief that police officers and other

00:38:20 belief that police officers and other public servants have specific duty to assist in inquiry. Whilst there are carveouts for existing legal prohibitions, the impetus for the bill, sir, is a recognition that state agents are duty bound to act with interailia,

00:38:31 are duty bound to act with interailia, transparency, cander, and frankness, to act without favor to their own position, and to make full disclosure. We therefore ask you to keep the graphan

00:38:42 therefore ask you to keep the graphan and spirit of the bill as well as the enshrined expected standards of ethical conduct at the forefront of your mind. This of course applies just as much to

00:38:57 This of course applies just as much to Mr. Francis, but he needs no reminder of that duty. I return now to David Hagen, also known as HN81.

00:39:04 as HN81. The very recent communication from the inquiry that 1881 will now not be giving it oral evidence uh is a blow to many

00:39:19 it oral evidence uh is a blow to many and a real challenge to the notion of accountability. We have no doubt sir that you did not make this decision lightly. However, Mr. Francis, however, for Mr. Francis, it is

00:39:32 however, for Mr. Francis, it is difficult to understand how HN81 is unable to come to answer questions despite being able to provide an incredibly detailed and lengthy witness statement relatively recently.

00:39:43 statement relatively recently. It I it now appears that the same can be said for HN86, although in relation to him without your approval. This is the worst of all worlds for all affected uh by these

00:39:56 worlds for all affected uh by these officers. There are those who are too unwell to participate at all and that is understood. HN123 for example. But to participate by producing a

00:40:10 But to participate by producing a self-serving witness statement like HN81 has running to some 77 pages and then say you cannot be questioned gives HN81 a somewhat special status creating

00:40:22 a somewhat special status creating unfairness to all he criticizes or accuses of lying. HN81 is plainly a significant traryy witness and one who has repeatedly contested Mr. Francis's

00:40:35 has repeatedly contested Mr. Francis's account of his tasking in respect of the Lawrence family campaign a as well as the intersecting allegations made against 1888 81 concerning his direct role in such surveillance through the movement for

00:40:52 surveillance through the movement for justice influence that Mr. Francis will not be afforded uh the opportunity via me or council to the inquiry to ask questions of so key a witness who has freely and repeatedly impuged his credibility and continues through his council to do so is unfair to Mr.

00:41:08 council to do so is unfair to Mr. Francis. Whatever is deemed fair to HN81.

00:41:10 HN81. It is worth noting that Mr. Sanders suggested that Mr. Francis's credibility should be looked at uh in the context of his poor mental health. And yet he does

00:41:25 his poor mental health. And yet he does not make that same acknowledgement about his own client's evidence. The absence of HN81 from the witness box will no doubt intensify the focus of Mr.

00:41:36 will no doubt intensify the focus of Mr. Francis's evidence. Despite the fact Mr. Francis has consistently stated that he had no contemporaneous knowledge of the connection between HN81 and the Steven

00:41:51 connection between HN81 and the Steven Lawrence family comp campaign during his SDS deployment only being made aware of this after he left the unit. Interestingly, all these years after Ellison, and as far as we are aware, for the first time in his new witness statement, HN81 says he does not agree

00:42:02 statement, HN81 says he does not agree with the description of him by Ellison as a spy in the Lawrence family camp. He was apparently more on I quote on the edges than the Ellison

00:42:23 on I quote on the edges than the Ellison report indicates and that crucial nuance he says between the wider Lawrence camp and the Lawrence family camp has been lost.

00:42:25 lost. Well, if he was coming to the inquiry, there would be so many questions to be asked about that assertion alone. For those justice groups on which HN81

00:42:36 For those justice groups on which HN81 reported, and for the Lawrence family in particular, his absence will no doubt be profoundly jarring and upsetting. In view of the fact that the findings of the Ellison review and the wider

00:42:47 the Ellison review and the wider questions this has raised about the extent to which inappropriate undercover activity was directed at the Lawrence family as well as HN81's undercover

00:43:02 family as well as HN81's undercover presence at the Steven Lawrence inquiry itself was a key precipitant for the government decision to hold this inquiry. It almost beggars belief that he will not be giving evidence. The fact that this news has reached Mr. Francis and the non-state

00:43:16 and the non-state non-p police core participants alike in September 2025 is unacceptable. Mr. Francis has no doubt that this decision will

00:43:31 doubt that this decision will unfortunately erode public confidence in this inquiry as well as the confidence of the Lawrenes and the black justice groups affected by SDS practices who have waited patiently for answers. We will return again to HN81 later. I want to move now uh to talk briefly about

00:43:47 to move now uh to talk briefly about some of the criticisms of Mr. Francis that have now been made in witness statements and openings we have seen in this tranch. It is important to make clear the basis on which Mr. Francis provides his evidence to this inquiry.

00:44:02 provides his evidence to this inquiry. As he confirmed in his opening back in 2020, he is not engaging with this inquiry as a campaigner of any sort. Whilst he inhabited the role of a dedicated left-wing activist for 5

00:44:15 dedicated left-wing activist for 5 years, he does not share the politics or attributes attributes of his former undercover identity. Mr. Francis can only assist this inquiry based on his direct experiences as a former

00:44:30 direct experiences as a former undercover officer, including what he learned from others while serving in special branch. In doing so, he has sought to provide an unvarnished account on all fronts, often in terms many may consider offensive. His evidence ranges across aspects of

00:44:49 His evidence ranges across aspects of SDS life that his former colleagues have shun from. For instance, the tac tacit acceptance of sexual relationships whilst employed undercover and the prevalence of racist tropes and attitudes within the SDS. Some may find his evidence, which he

00:45:06 Some may find his evidence, which he provides through the now long lens of an MPS undercover officer in the 1990s unsavory or objectionable. However, in the words of Mr. Francis, and I quote, "This is not some sort of

00:45:18 and I quote, "This is not some sort of expensive taxfunded popularity contest. He is determined not to sanitize his accounts of his UCA operation operations to appease any factions in this inquiry, nor to shore up his own whistleblower

00:45:30 nor to shore up his own whistleblower legacy or personal reputation, nor to try try and curry favor with you, sir, or indeed those who were spied upon. He

00:45:47 or indeed those who were spied upon. He comes to this inquiry in order to speak candidly in unflinching and unfiltered language in the interest of assisting this inquiry to establish an objective truth as to what happened. He fully

00:46:01 truth as to what happened. He fully anticipates being assailed on all fronts in giving his evidence in this phase of the inquiry. This comes with the territory of his status. He gets that much as he wishes they would. He does not expect the institution he exposed,

00:46:17 not expect the institution he exposed, nor those they spied upon to accept his evidence in his entirety. He has watched council to the inquiry interrogate various officers in the last tranches. He is expecting to have his

00:46:31 tranches. He is expecting to have his credibility robustly tested in a similar way.

00:46:33 way. And unlike officers HN81 and HN86, he is prepared to put himself through the ringer. All he asks is that the

00:46:49 the ringer. All he asks is that the allegations made against him are subject to the to equal challenge and scrutiny in return. And where an officer is not able or willing to face questioning, the

00:47:02 able or willing to face questioning, the weight of their untested evidence, where matters are factually disputed must be considered to be pretty light by you, sir.

00:47:14 you, sir. This is not the stage nor the forum to descend into a detailed tit fortat analysis of the shade that has been thrown at Mr. Francis in the written evidence of certain SDS officers and

00:47:27 evidence of certain SDS officers and non-state non-p police call participants disclosed to date in tranch three and cemented in their opening statements. We hope sir that you will forgive the use of modernday slang but it is of

00:47:41 of modernday slang but it is of opposite. The OED will tell you that throwing shade means to publicly criticize or express contempt for someone often in a subtle or indirect way. The contempt in some witness

00:47:53 way. The contempt in some witness statements is palpable in others more subtle and I'll come to some of that. But Mr. Francis expected this. As I've said, sir, no one in this inquiry

00:48:08 said, sir, no one in this inquiry actually likes the only whistleblower unless his account fits with their version of the truth. Returning to HN81, why would a man like him who is

00:48:19 why would a man like him who is suffering, he says, from the serious psychological effects of his time in the SDS, like Peter Francis? Mr. Francis's

00:48:32 SDS, like Peter Francis? Mr. Francis's disclosure has brought 1888 81's secret life back to haunt him even more and brought him nothing but grief. Perhaps he was learning to live with his past until Mr. Francis came along and blew

00:48:46 until Mr. Francis came along and blew the whistle. In his written evidence to the inquiry, he doubles down on the assertion he made to Ellison that he considers Mr. Francis a liar and makes

00:48:59 considers Mr. Francis a liar and makes various baseless allegations about Mr. Francis's conduct. This is no doubt because it was Mr. Franc's initial disclosure which inadvertently led to HN81's complicity being exposed in the

00:49:17 HN81's complicity being exposed in the Ellison review. And now, if that was not bad enough, he has pul he has been pulled into the glare of a public inquiry.

00:49:21 inquiry. And then there are the people who Mr. France spied upon. the Kingsway anti-fascist group, wiry and militant labor, whose statements are littered with references to him being a fantasist,

00:49:42 fantasist, who produced quote self arandizing and quote, embellished reports a in order to, I quote, amplify his perceived effectiveness. The statement from Mr. Francis's p primary target Lewis reads as a particularly splenetic

00:49:53 particularly splenetic if not wounded commentary punctuated with strangely personal insults such as

00:50:07 with strangely personal insults such as describing Mr. Francis as, and I quote, a sad and lonely outsider who was, I quote, a bit weird, boring, and sometimes annoying, and whom Lewis never really liked. In addition to that

00:50:19 really liked. In addition to that curiously personal statement, we have received a 62paged opening statement from those who represent those groups.

00:50:33 represent those groups. The entire document appears to be a character assassination of Peter Francis.

00:50:34 Francis. Indeed, sir, it reads like a personal poison pen letter to him and fails to really analyze the institution that put Peter Francis up to spying on them.

00:50:55 Peter Francis up to spying on them. Unlike many others who were spied upon, they blamed the man, not the organization. Extraordinarily, there is zero analysis of the institutional racism within the Metropolitan Police Service or the SDS

00:51:11 Metropolitan Police Service or the SDS um or the SDS justification for causing Mr. Francis to infiltrate such groups, which sir we say is quite odd given why the was formed. Their opening plays the man, not the ball.

00:51:27 man, not the ball. This type of evidence must be weighed against the understandable hurt and invasion people like Lewis now feel at having been spied upon by an individual. They allowed into their inner circle.

00:51:42 They allowed into their inner circle. They socialized together. They went to one another's houses and marched on countless anti-fascist demonstrations in union. They have a right to be angry.

00:51:57 union. They have a right to be angry. They were lied and invagled. Mr. Francis gets that he himself recalls feeling unexpectedly moved by the immense outpouring in support and sympathy he received from his wiry and militant

00:52:14 received from his wiry and militant targets in response to his cover story that his mother had died which is in fact only a ploy to enable his exit strategy.

00:52:16 strategy. The impact of learning that this individual was far from a brother in arms, but in fact an undercover officer, would no doubt be profound

00:52:30 would no doubt be profound and inevitably color their recollection of how they acted a and how they were perceived at the time. But also, quite frankly, they must feel

00:52:44 frankly, they must feel some anger, if not rage. They don't like the way they were depicted by Mr. Francis.

00:52:46 Francis. Hence the shadethrowing. It's a natural human and psychological response.

00:52:54 response. On closer review, however, the

00:53:05 On closer review, however, the assessments made of Mr. Francis by those in his target groups might well be considered contradictory, if not selfserving. For instance, whilst the statement labels Mr. Francis's reporting on this group as grossly inaccurate. It goes on

00:53:22 group as grossly inaccurate. It goes on to state in relation to his account that he was tasked to gather intelligence to undermine the anti-racist campaigns, including the Steven Lawrence family campaign, that I quote, "If Peter Francis's account is to believed,

00:53:34 Francis's account is to believed, and there is no good reason to doubt him, it appears that when the McFersonen inquiry was launched in response uh to the Metropolitan Police's failings, he

00:53:48 the Metropolitan Police's failings, he attempted wanted to expose what he had been asked to do as an undercover officer. That is, he tried to reveal the truth about the deliberate targeting targeting of anti-racist campaigns.

00:53:59 targeting of anti-racist campaigns. Even Lewis begrudgingly acknowledges

00:54:12 Even Lewis begrudgingly acknowledges that Francis's whistleblowing has been important in revealing the widespread abuses he and his fellow officers committed. This tenor of evidence illustrates the selective approach taken by those he

00:54:25 selective approach taken by those he spied upon towards Mr. Francis, seeking to endorse or refute his cred credibility dependent on how it aligns with their own narrative. This group however cannot have it both ways. Mr. Francis cannot be both a

00:54:42 ways. Mr. Francis cannot be both a trutht teller in respect of the wider methodologies and practices and misconduct of the SDS accepted by the MPS to be misconduct

00:54:53 MPS to be misconduct and yet a fantasist in respect of his own targets reporting. That tension we say is irreconcilable. Moreover, whatever might be said of him

00:55:12 Moreover, whatever might be said of him by his targets, there is ample evidence to demonstrate that Mr. Francis was a highly effective, valued undercover officer, whatever is thought about the justification for his targeting. The very fact he was able to become so

00:55:31 very fact he was able to become so trusted and so integral a member of the groups he infiltrated is indicative of his effectiveness. He did not choose these groups. His managers did. But he managed to become a branch secretary for both wire and

00:55:45 branch secretary for both wire and militant labor. The latter of which Hannah Cel accepts was a crucial position. The depth of Mr. Francis's surveillance and the value of the intelligence he was subsequently able to procure was consistently com commended

00:56:02 procure was consistently com commended by senior management and across uh his annual performance appraisals. The SDS 1995 to96 annual report reflects

00:56:19 The SDS 1995 to96 annual report reflects the very high value placed upon it. Albe it a gist, it states the following in respect of Mr. Francis, and I quote, "The first SDS officer ever to infiltrate this extremist left-wing organization. The officer enjoys privileged access to a range of intelligence and regularly

00:56:41 a range of intelligence and regularly assists ZE squad in providing accurate assessments of public order events in London. The security service acknowledges that his reporting on both policy and key activists provides an unrivaled informed and comprehensive coverage.

00:56:53 informed and comprehensive coverage. Whatever the criticism of Mr. Francis, you can't ignore those words. During his deployment, Mr. Francis was even

00:57:06 deployment, Mr. Francis was even directly tasked by the security services to provide intelligence on key members within militant at directly meeting with the security services several times. Amongst the various commendations he received following his deployment was

00:57:24 received following his deployment was the MI5 crest shield in recognition of his highly of his high-grade intelligence. It is significant to note that many of Mr. Francis's core disclosures, those he made all those years ago, which were tested by Operation Hannah as

00:57:39 tested by Operation Hannah as allegations have proven to be true. It is now widely accepted that the SDS engaged in sexual relationships with targets whilst deployed. Indeed, with it with at least one, namely Bob Lambert,

00:57:54 with at least one, namely Bob Lambert, knowingly fathering a child or perhaps fathering is the wrong language. it better to say knowingly made his target pregnant. A and also that the SDS used

00:58:06 pregnant. A and also that the SDS used deceased children's identities and the creation of their covert identities. Even the operational details such as the obtaining of falsified identity documentation including fake passports and driving licenses have been

00:58:18 and driving licenses have been corroborated by many officers uh accounts in previous phases to this inquiry as well as in the statements of HN81, HN15 and HM16 in this phase.

00:58:34 HN81, HN15 and HM16 in this phase. We uh have set out those similarities in written uh in detail in our written opening for your convenience. uh and I

00:58:51 opening for your convenience. uh and I don't repeat them now uh uh uh given the time I have. There is also considerable collateral evidence we say to support one of Mr. Francis's most prominent disclosures uh namely that as part of his deployment he was tasked to provide intelligence to undermine black justice campaigns including the Steven Lawrence family

00:59:02 including the Steven Lawrence family campaign. Bob Lambert has accepted in previous accounts that when a when a DI he provided Mr. Francis's intelligence on the family campaign to ex special

00:59:15 on the family campaign to ex special branch officer then acting detective inspector Richard Walton who was secundered to the MPS Lawrence review team at the time and involved in the Steven Lawrence inquiry. The Ellison

00:59:27 Steven Lawrence inquiry. The Ellison that Ellison found that HN81 was the MPS spy in the Lawrence family camp. However unpalatable that now feels to HN81

00:59:39 unpalatable that now feels to HN81 uh during the McFersonen inquiry. A a and um we now know he was directly reporting back uh to the SDS personal information uh about the Lawrence family is particularly significant. By this

00:59:52 is particularly significant. By this point, Mr. Francis was leaving the unit and HN81 had been deployed into movement for justice. The group uh which Kingsway anti-fascist group Mr. Francis's original target

01:00:04 original target um had transitioned into. Mr. Francis

01:00:15 um had transitioned into. Mr. Francis recalls meeting with HN81 uh in 1998 at the request of SDS management to brief him on his former targets and their relationship to the Steven Lawrence family campaign. HN81 emits any reference to this meeting in both his

01:00:28 reference to this meeting in both his interviews and in his evidence to this inquiry.

01:00:32 inquiry. And now, sir, we cannot press him on this omission. Whilst deeply disturbing and upsetting, Mr. Francis's disclosures do not appear to to those at the heart of the Steven

01:00:45 to to those at the heart of the Steven Lawrence family campaign to be difficult to believe. Dr. Neville Lawrence considers Mr. Francis's claim that SDS's officers held racist attitudes towards the Lawrenes, quote, not at all surprising.

01:00:59 quote, not at all surprising. set against the backdrop o of MPS institutional racism and misconduct that the Lawrence family directly experienced. And as Sir William McFersoness found in his report

01:01:16 McFersoness found in his report following the Steven Lawrence inquiry, Mr. Francis's disclosures are dispiritingly consistent. Sir Grover from the monitoring group no stranger to assessing the conduct of police officers recalls meeting Mr. Francis after M. McFersonen inquiry and

01:01:33 Francis after M. McFersonen inquiry and finding, I quote, that he came across as honest, genuine, and really concerned about the impact his work and the work of under undercover officers more broadly had on the Lawrence family campaign.

01:01:48 campaign. It will of course ultimately be a matter for you, sir, to assess and make appropriate findings about Mr. Francis's accounts. However, any suggestion from other officers that a tasking relating

01:02:01 other officers that a tasking relating to the Lawrence family lay outside the remit or ethos of the SDS must be looked upon with some skepticism in view of

01:02:17 upon with some skepticism in view of what is known about the practice of the SDS and Allison's own findings of HN81's,

01:02:18 HN81's, I quote, completely improper reporting of the Steven Lawrence family campaign to the Metropolitan Police Service. Mr. Francis stands to gain nothing

01:02:33 Mr. Francis stands to gain nothing personally from the various disclosures he has made over the years. He has made zero financial profit from the numerous media interviews he has provided or from the undercover book. Rather, these disclosures have come at

01:02:48 Rather, these disclosures have come at considerable personal expense to him and his partner. As we have already said, but we'll say again, his whistleblowing and the threat to prosecution under the official secrets act has greatly

01:03:03 official secrets act has greatly exacerbated his already significant psychological vulnerability. He has endured this process and the weight to give his evidence solely from

01:03:17 weight to give his evidence solely from a desire to lay bear his part in the SDS perpetrated deception. It is indeed difficult to conceive why any individual um would endure and in fact instigate

01:03:30 um would endure and in fact instigate such a process other than in discharge of the truth. What would he personally gain from it? Certainly not thanks or appreciation or friendship or support.

01:03:45 appreciation or friendship or support. None of that. Yes, he was angry with the SDS, but so are each of these undercover officers who were mistreated by them. That does not explain his motivation.

01:04:06 HN81 and Peter Francis both suffer with complex PTSD.

01:04:21 complex PTSD. HN86 has dissociated identity disorder. HN15 speaks of the long-term negative effects on his life and personality. HN12 HN123 is unwell. Tranch one and Trunch 2 open hearings

01:04:32 Tranch one and Trunch 2 open hearings were similarly littered with accounts of psychiatric damage suffered by undercover officers. For example, HN55,

01:04:46 HM4, and Mike Chitty. Whatever you think of these officers and their conduct whilst deployed, they were failed pre-eployment and then post deployment. The Metropolitan Police Service made

01:05:05 The Metropolitan Police Service made them seriously unwell and did nothing to support them afterwards. These failings are abject, inexcusable and unforgivable. Whilst the primary victims of SDS state surveillance are those who were spied upon, it is important to recognize that

01:05:24 upon, it is important to recognize that these officers were negligently deployed and effectively hung out to dry. The impact that intrusive and sustained surveillance has on those who were targeted has been and will continue to be a crucial facet of this inquiry and

01:05:37 be a crucial facet of this inquiry and rightly so. However, undercover officers such as Mr. Francis were also badly failed by the unit they had devoted uh devotedly served for many years. The

01:05:50 uh devotedly served for many years. The complete lack of pre and post-eployment welfare provision meant that officers coming off the SDS were left entirely alone, struggling to rehabilitate into their former lives. The psychological

01:06:07 their former lives. The psychological impact of such an unsupported transition was for many officers, including Mr. Francis, longlasting. Mr. Francis makes clear in his witness statement how the conditions for such psychological damage were sewn early

01:06:23 psychological damage were sewn early into an officer's deployment deployment. Before joining the SDS, Mr. Francis was required to sever all his links to his MPS life, including all contact with his

01:06:35 MPS life, including all contact with his former special branch colleagues. Having done so, he and his former colleagues were encou were were encouraged to, I quote, sweep swim as deep as possible in their target group. For Mr.

01:06:47 possible in their target group. For Mr. Francis and many others. This led to an experience of extreme submersion, compartmentalizing his former MPS career and his home life to such an extent that he would leave himself coded messages

01:06:59 he would leave himself coded messages reminding him to return home at the end of his deployment, a return home at the end of the week. Whilst this approach enabled him to swim deeply within an

01:07:18 enabled him to swim deeply within an insular group not previously infiltrated by the SDS, this set Mr. Francis up for immense psychological difficulty when the time came to finally resurface. A recurrent theme across the offic's statements in this phase of tranch 3,

01:07:30 statements in this phase of tranch 3, also reflected in tranches one and two, is the distinct lack of training or psychological preparation that they were provided with before being deployed. The

01:07:41 provided with before being deployed. The extraordinary levels of secrecy and deni deniability that informed the unit resulted in officers being left woefully underprepared for the realities of the job. Mr. Francis is Mr. Francis is clear

01:07:56 job. Mr. Francis is Mr. Francis is clear that the mechanisms in place at the time to assess an officer's suitability psychological and otherwise for so deep an undercover role were wholly inadequate. Many officers who were approached to

01:08:11 Many officers who were approached to join the SDS were already in some ways vulnerable being attracted by such an extreme and isolating role in order to escape from personal problems.

01:08:30 Mr. Francis has frankly revealed that he was unhappy at home and saw the job as an escape, though later realizing he went so deep into his UC UCO role because I quote uh uh because I wanted a different life to what I had at home. Despite this, no substantive

01:08:41 Despite this, no substantive psychological assessment or vetting was undertaking was undertaken prior to his deployment. No advice was offered to him as to the likely psychological impact of such work or its impact on his personal

01:08:54 such work or its impact on his personal and family life. Mr. Francis was simply directed to speak to certain SDS former officers who cautioned him in general

01:09:11 officers who cautioned him in general terms that he may struggle. He was also given very limited information about what the unit was, what he would be doing.

01:09:15 doing. Looking back, he feels he was simply not equipped with enough or accurate information to understand how extreme a psychological impact the work would have. He is not alone in this thinking.

01:09:37 have. He is not alone in this thinking. The statements of Mr. Francis HM 15, 16, and 81 are all similarly underscore the highly limited training they received before being deployed. A great deal of what he picked up about legend building, for example, was in

01:09:49 legend building, for example, was in fact gleaned from his journeys driving H86.

01:09:50 H86. As you know, he was the DCI in charge of

01:10:02 As you know, he was the DCI in charge of the unit at the time um at the time that Peter Francis was deployed uh um to and to and from work each day. Uh none of these officers can recall being directed or tested on the key SDS policy documents or guidance uh in placed at

01:10:17 documents or guidance uh in placed at the time such as the code of conduct or SDS guidelines regarding the participation in crime. SDS officers were also provided with little

01:10:28 were also provided with little operational guidance on how to carry out their taskings. Mr. Francis recalls being uh given a lot of autonomy over over his D daily UCO activities. HN81

01:10:40 over his D daily UCO activities. HN81 states that a great deal was left to his discretion. Whilst general guidance was given on the threshold of criminality, this was decidedly broad being a matter of

01:10:51 decidedly broad being a matter of personal judgment to assess whether the action was proportionate and necessary to maintain cover. HN15 says there was no, and I quote, hard and fast rule.

01:11:02 no, and I quote, hard and fast rule. Whilst minor criminality was tolerated, there was no shared understanding as to where the line was drawn. Mr. Francis recalls receiving no

01:11:23 Mr. Francis recalls receiving no guidance at all on to what extent it was acceptable uh to become involved in the private lives of those they met whilst undercover or the proximity of such relationships. There were no discussions of the ethical parameters of their

01:11:34 of the ethical parameters of their behavior, nor clear guidance given about sex undercover or ill or or infiltr infiltrating specific groups such as for instance black justice campaigns or trade unions.

01:11:50 trade unions. For such a highly secret unit which encouraged its officers to be deep swimmers to immerse themselves completely within their cover identity and target groups. The absence of such guidance or preparation appears

01:12:02 appears deliberate. The less informed they were about their role or the parameters or standards required, the deeper their surveillance

01:12:13 required, the deeper their surveillance may be. As Mr. Francis bluntly puts it, and I quote, "We referred to the SDS as mushroom undercover policing because we

01:12:26 mushroom undercover policing because we were kept in the dark and fed bullshit."

01:12:34 The psychological dislocation that SDS officers faced on leaving their undercover roles was wholly predictable. Having been cut off from their MPS lives for so long whilst living a state sanctioned double life, the process of

01:12:54 sanctioned double life, the process of assimilating back to their true identity was both sensitive and complex. Despite this, Mr. Francis described how exfiltrated officers were expected to, I quote, come immediately out of it once it was over.

01:13:07 it was over. He was provided with no psychological or welfare support whatsoever from either the SDS or MPS. After leaving the unit, he was left struggling to reintegrate

01:13:19 he was left struggling to reintegrate into special branch and back to being Peter Francis. His requests for help were met with indifference despite still being under the supervision of the same management team he had on the SDS,

01:13:31 management team he had on the SDS, including the implication that such mental health issues were a sign of weakness.

01:13:43 Mr. Francis was finally signed off sick in September 1999 after suffering a mental health breakdown. This is well

01:13:54 mental health breakdown. This is well known. Only after this and from his own initiative does he did he receive any psychiatric support. He was subsequently medically retired from the MPS in 2001,

01:14:07 medically retired from the MPS in 2001, having been diagnosed with complex PTSD, the direct cause of which was his undercover work. Mr. Francis was forced to have recourseed litigation against

01:14:19 to have recourseed litigation against the MPS to get them to finally recognize the significant psychiatric damage they had caused him with his case settling in 2006.

01:14:27 2006. Both HN16 and 81 described similar experiences of a complete lack of any SDS post operation welfare or psychological support.

01:14:44 psychological support. In the absence of any reciprocal mental health support from the SDS, these officers were left behind in the psychological shadows. Mr. Francis's Mr. Francis hopes that by

01:15:00 Mr. Francis's Mr. Francis hopes that by giving evidence in this inquiry, it may bring him some sense of closure and reconciliation in his long journey back to becoming the original Peter Francis fully again. He's come a long way towards finding himself

01:15:16 come a long way towards finding himself again, but um finally giving his account in public is an essential step to fulfilling that journey. He hopes that the inquiry draws from his experience the immense psychological burden

01:15:30 the immense psychological burden shouldered by those who undertake undercover work. Mr. Francis has entirely properly been described in the media as a whistleblower since his initial disclosures.

01:15:42 disclosures. There is no doubt that he has made disclosures of wrongdoing in the public interest. However, undercover officers like Mr. Francis are in fact disbarred from blowing the

01:15:58 in fact disbarred from blowing the whistle. Mr. Francis's plight reflects the fundamental tension between the official secret act official secrets act and the general acceptance by the public that whistleblowing of this kind should

01:16:11 that whistleblowing of this kind should be treated as a protected disclosure in the public interest. Undercover officers are in practice gagged from speaking up about wrongdoing and remains down to the institution to

01:16:27 and remains down to the institution to determine whether and to what extent any past wrongdoing should be made public. We have set out the attempts at legislative protection in our written opening, but I will uh uh not repeat that uh now, sir, but of course we ask you to consider it.

01:16:40 you to consider it. In conclusion, sir, Mr. Francis has stuck his head significantly above the parapit without any whistleblower

01:16:56 parapit without any whistleblower protection and without any psychological support associated with his whistleblowing. To this day, the Metropolitan Police Service still do not recognize him as a

01:17:19 Service still do not recognize him as a whistleblower. Despite the misconduct he has uncovered, he has he has suffered a significant detriment for the greater good. This needs to be recognized by you, sir. It is vital, we say, that you grapple with the conflict between whistleblowing and the

01:17:34 conflict between whistleblowing and the official secrets act, the current lacuna in the law. and we will urge you in due course to make recommendations to fill that gap to properly protect the public. If that gap is not filled, Mr. Francis

01:17:49 If that gap is not filled, Mr. Francis will have sacrificed his mental health and at least the last 10 years of his life for almost nothing. And by that he means without embedding protection for future whistleblowers

01:18:06 protection for future whistleblowers which we say is in the public interest. Thank you sir. Thank you very much indeed. I look forward to hearing the oral evidence of your client. Um, I will bear in mind

01:18:20 your client. Um, I will bear in mind what you have told me in your opening statement when listening to it. Thank you.

01:18:27 you. Thank you very much, sir. We're grateful.

01:18:37 Now, you're being cut off and uh I invite uh Miss Murphy, Kings Council, uh to make her oral opening in uh support of the category F uh core participants. Miss Murphy,

01:18:48 participants. Miss Murphy, good morning. I'm grateful. So, good morning.

01:18:52 morning. This opening statement is made on behalf of the category Families who are the bereaveved relatives of loved ones who died in childhood and whose legal

01:19:03 died in childhood and whose legal identities were appropriated by the Metropolitan Police. Lisa and Mark Crossland are the bereaveved stepmother and brother of Kevin Crossland, whose identity was appropriated by former Detective

01:19:19 appropriated by former Detective Sergeant Thompson, an officer from whom you will hear in this phase. Frank Bennett and Anna Robson, Faith Mason, the Lewis family, Emma Richardson, the

01:19:32 the Lewis family, Emma Richardson, the daughter of Barbara Shaw, and a family designated the restricted family. And the inquiry has committed to providing

01:19:46 the inquiry has committed to providing an opportunity to address you separately concerning their particular experience. So you are familiar with the suffering of the families. In trunch one, you explore the origins of the practice and in tranch two, the continuence of it

01:20:02 in tranch two, the continuence of it within the lawless clique of undercover police officers that was the SDS. You have our submissions. First, that there was no good reason, justification or necessity for the adoption of the practice.

01:20:14 adoption of the practice. Secondly, that the choice of senior and junior officers alike to ignore the obvious legal, moral, moral and ethical appearance of the practice in preference the vain hope that the families would

01:20:29 the vain hope that the families would never find out reflected the morality of the kindergarten. And you sir have concluded in your tranch one interim report that the very fact that public approprium would rain down on the SDS practices if exposed

01:20:43 down on the SDS practices if exposed delegitimated the entire enterprise. It has also been a theme emphasized by the families from the outset that

01:20:57 the families from the outset that properly understood the motivation of the SDAS officers, both senior and junior, were far from the high-minded pursuit of public safety of which certain witnesses have sought to

01:21:12 certain witnesses have sought to persuade you, but rather and apparently the SDS's own self-perpetuation concealment of its disgusting secrets and the prevention of any form of public accountability.

01:21:24 accountability. That sir is the evidential thread to which the family invite your closest scrutiny in this phase.

01:21:44 It was in 94 1994 that the SDS purported to formally discontinue the practice of using dead children's identities. In the 9495 SDS annual report, Detective Chief Inspector Keith Edmonson acknowledged

01:21:55 Inspector Keith Edmonson acknowledged that fictitious identities where a more secure option. Quote, "The adoption of

01:22:06 secure option. Quote, "The adoption of purely fictional cover identities has an overriding advantages advantage for the security of the SDS operation. Faced with suspicion and distrust, a field officer may never satisfy a hostile inquirer who has reason to

01:22:20 hostile inquirer who has reason to believe he has unc uncovered a police informer.

01:22:23 informer. If the inquirer is unable to reach a definitive conclusion, as in finding a death certificate for the person under suspicion, he remains dealing with the more general problem of a possible

01:22:38 more general problem of a possible informer as opposed to an undercover spy.

01:22:39 spy. And in the same report, DCI Edmonson also reported that quote, "Management have conducted a thorough review of all

01:22:51 have conducted a thorough review of all cover documentation available to support a field officer's bonafidees. One established practice has been discontinued and new procedures have been introduced," unquote.

01:23:02 been introduced," unquote. We note that this review has not been made available to the families who are unclear whether it has been lost, destroyed or withheld. But you are invited to note, sir, the

01:23:15 But you are invited to note, sir, the emphasis there upon the sec security of the SDS operation. The families note and welcome the

01:23:26 The families note and welcome the commissioner's acceptance in his opening statement to this phase that reliance upon fictitious identities could and should have been adopted before this review.

01:23:42 review. But challenge his assertion that DCHN26 was the first SDS UCO to use a fictitious identity. It appears that this misunderstanding is derived from the 9495 annual report. But

01:23:57 derived from the 9495 annual report. But as you will recall, sir, the SDS did use fictitious identities between 1968 and 1974.

01:23:59 1974. And that, for example, HN56 used a fictitious identity during his 1990 to 1991 deployment. And you would recall, sir, that the

01:24:14 And you would recall, sir, that the tradecraft manual proposed a choice. The families seek thorough in investigation of those aspects, including the circumstances in which the practice came to be discontinued.

01:24:26 practice came to be discontinued. The computerization of records may prove to be an insufficient or incomplete explanation given the detailed history that you have explored. At any rate, the practice had by this point had senior level endorsement for

01:24:42 point had senior level endorsement for two decades. And at paragraph nine and 10 of our written opening statement, we have set out the evidence you have heard from senior managers on this aspect up to de deputy assistant

01:24:54 aspect up to de deputy assistant commissioner level. That evidence reflects a wholesale fail failure over the entire period to apply any semblance of moral or legal scrutiny.

01:25:09 of moral or legal scrutiny. The review and discontinuence in 1994 was tardy at best. Three years earlier in the 1991 annual

01:25:20 Three years earlier in the 1991 annual report, it was noted that the birth and death death records were being computerized. And that event was noted in the Treadcraft manual to have added to the growing unease, not about the legality

01:25:36 growing unease, not about the legality and morality of the use of the practice, but its security, especially regarding the unmasking of the SDS. And reference is also made there to quote many earlier fears regarding the practice.

01:25:48 practice. And the tradecraft manual also makes reference the need to change operating procedures quote without delay in light of the computerization.

01:25:59 of the computerization. We write we invite you therefore to investigate the operational response to the computerization of records and to

01:26:11 the computerization of records and to conclude that there was in fact no sense of urgency and that the attitude to the families is truly reflected in the flippant and degrading references that are made to them in in the tradecraftraft manual.

01:26:22 tradecraftraft manual. The families also invite you to note that there is no explicit reference to the practice in the SDS closure report prepared in June 2009.

01:26:34 prepared in June 2009. The only reference to cover identities is on page 68 when HN273 recommends that the MPS ordered uh it's largely redacted but identity documents arising from historic covert identities.

01:26:55 arising from historic covert identities. Again, the documentary product if any um of of that audit has not been made available if it occurred.

01:27:03 Looking at the matter broadly, the explanation can only be that the Metropolitan Police Service remained completely oblivious to the reputational risks associated with the practice or they were aware of those risks but

01:27:17 they were aware of those risks but deliberately made no reference to them in that closure report. And so the families seek close investigation in tranch three of the following questions

01:27:28 tranch three of the following questions which remain for the Metropolitan Police Service.

01:27:34 Service. Why did it take two decades for review and discontinuence of the practice? To what extent did the SDS managers ever reflect on the moral, legal, and ethical implications?

01:27:49 Whether in the mid 1990s review or at the point of closure, and what were the circumstances leading to review of the practice and the authorizing of the change to the practice?

01:27:59 practice? Did the intention and imperative of keeping the practices of the SDS secret

01:28:13 keeping the practices of the SDS secret contribute to circumstances in which the SDS continued to operate outside legal and ethical mores and what are the implications for contemporary under cover deployments.

01:28:29 cover deployments. We turn next to the evidence of Peter Francis about which user had just um been hearing from Miss Sakan King's Council. The families have set out in their opening and closing statements to

01:28:40 their opening and closing statements to Trunch 2, the evidence which has emerged about how UCOs identified a dead child and the research they undertook in the preparation of their cover legends. Unconvinced by blanket denials of

01:28:55 Unconvinced by blanket denials of research into the families, they have set out the evidence from which the inquiry is invited to conclude that researchers were in fact carried out.

01:29:06 researchers were in fact carried out. That's addressed at paragraphs 14 to 17 of our closing statement for Trunch 2. The families observed at that point the potential significance of Mr. Franc's

01:29:18 potential significance of Mr. Franc's evidence in revealing the extent of SDS research

01:29:20 research as he is the only SDS UCO to have

01:29:31 as he is the only SDS UCO to have demonstrated an apparent willingness to reveal the truth of SDS practices and he has confirmed that it was standard practice to use as many aspects as possible of the child's identity as were available and he has stated that it cannot not

01:29:44 and he has stated that it cannot not accept that other SD officers would have only used the name. He states, quote, we were encouraged to take on the birth

01:29:56 were encouraged to take on the birth certificate of someone somebody else to prevent us being discovered. So, of course, we would also have to take all the details that came with that. And he added that quote, it was standard

01:30:13 added that quote, it was standard practice to investigate the background a bit. and quote, "Other officers visited where the children had been born." His backstory was tested by HN86 in the car journeys to and from work. He would quote, "Write it out. He would read it

01:30:30 quote, "Write it out. He would read it and give me notes to enhance it, and I would improve it." My backstory was a couple of A4 pages. The families therefore await his oral evidence with interest and hope this will afford an opportunity to learn more about the

01:30:44 opportunity to learn more about the detail of the practice. It is hoped that this will include details of the identity of others who were familiar with the extent of the interference including his knowledge of other UCOs's

01:30:56 including his knowledge of other UCOs's practice in developing their identities based on dead children. The families are keen to know what research the UCOs carried out into them, whether the documenting of the cover

01:31:08 whether the documenting of the cover legend on paper was general practice, the attitudes of the UCOs and managers to the practice, and the extent of any appreciation or lack thereof on the

01:31:23 appreciation or lack thereof on the unlawful and unethical basis for the practice.

01:31:25 practice. Our next topic, sir, concerns the Crossland family and the conduct of former detective Sergeant James Thompson.

01:31:37 Thompson. Kevin Crossland was only 5 years old when he died in a plane crash with his mother and sister in 1966. His father David was the sole survivor

01:31:48 His father David was the sole survivor from the family and David later went on to remarry um with Lisa Crossland and to have another son Mark. The loss of

01:32:05 have another son Mark. The loss of Kevin, his mother Daphne, and his sister Lynn was a constant shadow over the Crossland family. And David consciously ensured that his surviving his his son Mark knew of and felt a connection to his deceased

01:32:21 felt a connection to his deceased siblings, Kevin and Lynn Crossland. David sadly died in November 2001. And it has come as a profound shock to Mark and Lisa Crossland to discover that earlier in 2001,

01:32:33 earlier in 2001, while David was suffering from cancer, James Thompson may have paid detective agencies to carry out research into Kevin's identity.

01:32:47 Kevin's identity. They were similarly appalled to learn that at about the same time, James

01:32:58 that at about the same time, James Thompson was procuring various documents in Kevin's identity and it would appear giving Kevin's name to police when arrested.

01:33:03 arrested. Mark describes Thompson's actions while his father was dying as depraved. Lisa Crosslin states that she felt quote shocked, confused, and disgusted.

01:33:14 shocked, confused, and disgusted. Both have described their confidence in the police being profoundly undermined. They seek answers on behalf of David knowing that he would have wanted justice for Kevin.

01:33:31 justice for Kevin. They are pessimistic that James Thompson will answer their questions. His evidence to your inquiry and to the

01:33:45 evidence to your inquiry and to the earlier investigations is contradictory, inconsistent, and wholly unreliable. SDS managers observed during investigations in April 2002

01:33:56 investigations in April 2002 that he had an inclination, quote, to admit only that with which he is confronted. Distrustful of Thompson's earlier recounts, the Crossland family still hope to learn in these hearings how and

01:34:10 hope to learn in these hearings how and why he came to rely on Kevin's identity and why his unsanctioned actions went apparently unnoticed by his managers for so long.

01:34:23 so long. They also doubt the integrity of the SDS investigations into James Thompson's actions as he was neither prosecuted nor formally disciplined for his unlawful and unsanctioned appropriation of

01:34:35 and unsanctioned appropriation of Kevin's identity. And not only was he allowed to continue to serve with the Metropolan Police Service after his misconduct came to light, but his

01:34:46 misconduct came to light, but his security classification was restored and he was authorized to serve as a firearms officer.

01:34:54 officer. That chronology informs you, sir, regarding the extent to which there was in fact any real concern for the safety

01:35:07 in fact any real concern for the safety of the public within the SDS management. In relation to why he used Kevin's identity, James Thompson has given multiple accountants. On 19th March 2002,

01:35:21 On 19th March 2002, he told Detective Chief Superintendent Colin Black that he had created a fictitious identity in Kevin's identity because quote, "He knew at an early stage that his extraction from his area

01:35:33 stage that his extraction from his area of work would not be properly handled by the office and he therefore felt that he had to take steps to ensure his operational safety."

01:35:49 On 4 April 2002 at a meet meeting with HN53

01:35:51 HN53 and MD, he maintained that he had created an identity based on Kevin to facilitate his travel to the USA as part of his exfiltration strategy.

01:36:05 of his exfiltration strategy. MD therefore informed James Thompson that he would be reported for lying if he maintained that accounts because they

01:36:20 he maintained that accounts because they were aware of evidence that Thompson had constructed Kevin's identity at least 2 years earlier. He then changed his story when he wrote a post operational debrief in 2002 claiming that he had created the

01:36:35 claiming that he had created the identity so that he had an alternative to offer police if arrested whilst undercover and this was necessary to be accepted by his target group.

01:36:52 Limited additional information has been provided in his statement to your inquiry.

01:36:58 inquiry. He claims that quote at the time of my recruitment to the SDS he understood from ex field officers that quote the method of using a dead person's name to create one's cover identity was still the practice

01:37:14 identity was still the practice and that he took the birth certificate of Kevin Crossland with him from the special branch but does not think he discussed this with his SDS managers

01:37:32 discussed this with his SDS managers because quote I did not need to use it. Then he would have it after he became aware of activists using false identities when arrested. He considered developing a false identity from Kevin's birth certificate for that purpose.

01:37:45 for that purpose. And it is his evidence to the inquiry that he added Kevin's name and his undercover address to the voters's register because bail was conditional on a voter's check.

01:37:56 a voter's check. He then states that his actions are attributable to a dissociative identity disorder and head injuries he suffered

01:38:10 disorder and head injuries he suffered in the early stages of his deployment. And he states that his perspective became increasingly lost towards the end of his deployment as he became subsumed by an irrational desire to save his undercover identity, James Straven.

01:38:24 undercover identity, James Straven. And he states that he cannot offer a rationale for what he did because quote they were the result of the decision-making of someone suffering a mental illness.

01:38:39 These accounts are not considered plausible, nor are they easily reconciled with the objective evidence. The Crossland family do not accept them and observe that

01:38:54 and observe that SDS UCOs were schooled in tradecraftraft by current and former UCOs which as you have previously heard created an environment in which bad

01:39:05 created an environment in which bad practices were passed on and implicitly endorsed.

01:39:07 endorsed. James Thompson was not the first to acquire an unauthorized second identity in the name of a deceased child. John Dyn's HN5

01:39:25 John Dyn's HN5 conceded to the inquiry that he gave the name of a deceased child when he was arrested. And you will recall the evidence of Helen Steel that he had cover documents in at least two other cover names.

01:39:36 two other cover names. Andy Kohl's admitted to providing false identities again in the names of deceased children to activists in his cover group. James Thompson deliberately in Lisa and

01:39:47 James Thompson deliberately in Lisa and Mark Crossland's submission neglects to name the officers who advised him about the practice.

01:39:58 the practice. He provides no explanation as to how he obtained Kevin Crosslin's birth certificate, stating that he only recalls, quote, "The requested birth certificate sitting in my trays until I

01:40:12 certificate sitting in my trays until I was eventually recruited into the SDS." He hypothesizes, as he states he cannot remember, that he may have researched the identity as part of his duties as a junior special branch officer.

01:40:27 officer. He fails to explain why on his account he obtained a copy of the bear certificate nor why he kept that copy in his trays for potentially 5 years. Uh we note that the bar certificate

01:40:45 Uh we note that the bar certificate relied on is dated the 9th of July 1991 but James Thompson joined the SDS in 1996.

01:40:47 1996. If is his accountant is true, this would be consistent with wider abuse of use of the practice within special branch.

01:41:02 the practice within special branch. Significant questions therefore remain concerning this protract protracted timeline of events. Kevin's family note first certified copy of the bar certificate um as I've mentioned uh w was issued

01:41:14 um as I've mentioned uh w was issued five years before he joined the SDS. Kevin Crossen's name was added to the electoral register by Thompson in 2000, four years into his deployment.

01:41:29 four years into his deployment. uh then registered for electricity and banking facilities in 2001 and thirdly a provisional driving license was issued to him in Kevin's identity in March 2002.

01:41:49 James Thompson's deployment of a further cover identity in Kevin's name was evidently not a spontaneous act, but was part of a protracted

01:42:01 part of a protracted plan implemented, it would appear, at various stages over those two years. He posits that his actions were driven by concerns regarding his security,

01:42:13 by concerns regarding his security, but he did also take grave risks during and after his deployment, including traveling on a passport, which he had personally tampered with by removing pages so as to deceive his managers.

01:42:31 using a telephone registered in Kevin's name to call contacts known to him in his rail and cover identities and maintaining contact with activists he targeted for a protracted period after his deployment.

01:42:42 his deployment. Detective Chief Inspector Michael Dell was critical of Thompson's quote shoddy tradecraft involving contamination of rail and operational identities.

01:43:05 You have heard evidence of the purportedly close supervision of UCOs, particularly when arrested.

01:43:14 Thompson must therefore have been aware that providing a deceased child's name as his cover identity during arrest would have come to the attention of his supervising managers. and he admitted to giving the name of Kevin Crosslin to police in Surrey or Sussex on two

01:43:26 police in Surrey or Sussex on two occasions when detained by the police.

01:43:42 He must have either been confident that his managers would endorse his conduct or at a minimum prove indifferent to this conduct. James Thompson has not to date offered any explanation as to why he would have acquired the birth certificate long before joining

01:43:59 birth certificate long before joining the SDS. How he went about obtaining it, how long it took him to do so, and how he managed to carry out this work while also purportedly discharging his special branch duties.

01:44:18 The Crossland family therefore look to you, sir, to closely scrutin scrutinize and investigate um this chronology in the course of the evidence that you will hear in this phase

01:44:36 hear in this phase um on the current evidence as available. These facts are a grave illustration of wider failures to supervise SDS undercover officers. Even though painfully aware of the consequences of SDS UCOs's misusing

01:44:50 consequences of SDS UCOs's misusing their cover identities following the Stefan Scutter and Mike Chitty experience,

01:45:03 experience, James Thompson was able to misuse cover identities over many years. It wasn't until March 2002 that SDS managers apparently discovered that he had created an identity under the name of Kevin Crossland. Over two years earlier by chance after his admission that he had defaced his

01:45:18 his admission that he had defaced his cover passport led to an investigation into his use of identity documents in the names named James Straven. Uh, and James Thompson gave the name Kevin Crossland when he was arrested.

01:45:29 Crossland when he was arrested. Um, although he cannot now recall whether he informed his managers, but these are all clear examples of obvious failures in supervision and oversight.

01:45:45 In that period between January 2000 and March 2002, Thompson meanwhile produced only 21 intelligence reports which was significantly less than his contemporaries. Uh which is also

01:45:58 contemporaries. Uh which is also indicative of a lack of management oversight over his deployment. The SDS closure report observes that there was quote a lack of intrusive management which resulted in quote alarm bells

01:46:17 which resulted in quote alarm bells being missed. And the author author goes on to note that a UTO who received little welfare support was sub subsequently the subject of an internal investigation and that is likely to be a reference to James Thompson. But even if not, the broader observations regarding

01:46:30 not, the broader observations regarding a lack of sufficient management and the failure to identify alarm bells apply to him as they would to any other UCO. What is clear is that John James

01:46:48 What is clear is that John James Thompson's behavior fell significantly far of the standards of professional behavior expected of a serving Metropolan police officer at the time and descended into obviously illegal and unauthorized activities.

01:47:09 Um, HN9 told Operation Hearn that in light of James Thompson's conduct, he expected him to be arrested and he provided Detective Chief Superintendent

01:47:21 provided Detective Chief Superintendent Colin Black with a card setting out the relevant caution for this purpose. Um, DIHN53 drafted a note listing the criminal offenses which appear to have been committed by him.

01:47:34 Despite this,

01:47:42 um, a detailed investigation uh, purportedly detailed investigation into his actions by SDS managers resulted in quote informal discipline only.

01:47:54 quote informal discipline only. A report by DCI Dell in March 20 confirmed

01:47:57 confirmed that the SDS preference for informal discipline over a formal disciplinary process including arrest and charge um

01:48:11 process including arrest and charge um arose because of the benefits of quote maintaining the integrity of the SDS operation

01:48:13 operation outweighed those offenses including neglect of duty, impropriy, lack of supervision, failure to comply with Reaper, prejudice to morale,

01:48:27 Reaper, prejudice to morale, vulnerability uh to embarrassment of the Metropolitan Police Service. Uh and all this um arising in the context of the strong likelihood that

01:48:42 context of the strong likelihood that his abuse of Kevin's identity grew out of a broader apparently authorized historical abuse of the identities of dead children within the SDS.

01:48:57 dead children within the SDS. James Thompson was effectively shielded from prosecution and formal discipline for his actions and the only consequences were that his vetting status was temporarily reduced and he

01:49:08 status was temporarily reduced and he was assigned administrative duties again temporarily. The responsibility of the relevant senior officers to comply with the legislation,

01:49:22 legislation, regulations, and associated guidance are matters that the family seek to have fully explored. Uh the consequences of course was that James Thompson was free to continue to serve in the Metropolitan Police until June 2014

01:49:34 June 2014 and he appears thereafter to have persisted in developing unauthorized covert identities.

01:49:45 covert identities. He told your inquiry, sorry, HM56 told your inquiry that after Thompson's deployment end ended, he again tried to obtain a cover uh a driving license um for a copy of his cover driving

01:49:57 um for a copy of his cover driving license for quote nefarious purposes and HM56 could not recall the name the cover driving license was in. Um, however, this incident was not reported to SDS

01:50:12 this incident was not reported to SDS managers, uh, as HM56 assumed they were already aware.

01:50:20 Uh, and we note the document recording that Bob Lambert supported James Thompson's promotion. Nevertheless, the context is unclear, but the Crosen

01:50:31 the context is unclear, but the Crosen family emphasize that James Thompson was supported by a senior manager for promotion despite having been identified as having committed criminal offenses during the course of his deployment. And note that James Thompson suggests that

01:50:50 note that James Thompson suggests that if Di Lambert was still responsible for the SDS at the end of his deployment, quote, it might have gone very diff differently. Um, the families expect this issue to be thoroughly investigated.

01:51:02 investigated. So the Crossland family sir looked to the inquiry to investigate how and when

01:51:16 the inquiry to investigate how and when did James Thompson learn of the practice and what assistance andor encouragement did he gain from within the SDS? What was the relationship with Metropolitan Police special branch? What were the circumstances in which he paid private detectives to run checks and the extent to which any other forms of

01:51:30 extent to which any other forms of research were undertaken in relation to the Crossland family? How could he use and rely on Kevin's identity over a period of years without managerial intervention?

01:51:41 managerial intervention? Why did he not face appropriate prosecution and/or disciplinary action when several criminal and disciplinary offenses have clearly been identified?

01:51:56 offenses have clearly been identified? And what were the broader circumstances surrounding the use of informal discipline and his subsequent rehabilitation within the Metropolitan Police despite the obvious alarm bells? The boundary between identity

01:52:10 The boundary between identity appropriation which was authorized and that which was not is in our submission an important area for your investigation. Sir

01:52:27 Lisa Mark Crossland acknowledge the Metropolitan Police statement of support.

01:52:31 support. I'm afraid you've overrun and timetable our timetable is tight and I must I'm terribly sorry sir. Um I I'm just going to I'm almost finished. I'll be about 2 minutes.

01:52:48 Um yes, they acknowledge the support for their objectives of receiving answers and accountability but reiterate their demand for corporate evidence regarding institutional knowledge.

01:52:59 institutional knowledge. The investigation of the circumstances surrounding the discontinuence of the DCI practice during the trunch 3 period offers opportunity to clarify the roots of the institutional malaise that

01:53:10 of the institutional malaise that facilitated the appalling practices of the SDS. It is notable that the review which led to the discontinuence was informed by practical considerations.

01:53:21 informed by practical considerations. The families invoke invite the inquiry to focus in its investigations upon the lack of oversight and any form of effective scrutiny. It remains one of

01:53:32 effective scrutiny. It remains one of the more shocking aspects of the SDS's history that so many senior officers and UCOs consider uh continue to consider

01:53:46 UCOs consider uh continue to consider that the expectation that the families would not find out was sufficient to justify the appropriation of dead children's identities. The public rightly expects the MPS to maintain high ethical standards, but is increasingly

01:53:59 ethical standards, but is increasingly apparent as this inquiry commences its third trunch that cloaking the SDS in secret secrecy and depriving it of any form of public scrutiny or

01:54:14 form of public scrutiny or accountability facilitated the SDS to descend into yet further depths. Thank you, sir. Thank you. Uh we will now rise. um for I'm afraid a slightly short 15 minutes. We will resume at quarter 2.

02:05:37 Miss Gilroy, sir,

02:05:39 sir, as you know, I represent the women deceived into sexual relationships by undercover officers or UCOs employed by the SDS.

02:05:52 the SDS. These women are known as the category 8 CPS.

02:05:54 CPS. In this trunch, I also represent Wendy, who at a very young age was groomed by a UCO and deceived into a long-term friendship with him.

02:06:10 friendship with him. The inquiry has already heard evidence about dozens of abusive sexual relationships during the previous 25 years of the SDS's existence. From 1968 to 1993,

02:06:30 we have heard about young and often vulnerable women tricked into sex and deeply intimate relationships. We have heard that for some of these women, a UCO was their first boyfriend or first serious boyfriend.

02:06:46 or first serious boyfriend. that some women were seduced by UCOs after previous relationships or childhoods scarred by violence, tragedy or neglect. We have been told that many women

02:06:59 We have been told that many women thought they had found partners for life, fathers to their future children, soulmates and companions.

02:07:13 We have also heard about the many false stories the police officers told them. Fantasies, invented political opinions, and outright lies about the feelings they had.

02:07:32 they had. Hard luck stories of abuse and family discord, a murky criminal past left behind.

02:07:37 behind. These stories were designed to ent trap women, enlist their sympathies and

02:07:50 women, enlist their sympathies and deepen their emotional connection and at the same time to confuse them and to justify the absence of parents and siblings.

02:07:52 siblings. We have seen that the emotional manipulation did not stop then. UCOs made declarations of love and commitment, passion and jealousy.

02:08:05 commitment, passion and jealousy. And the women they deceived relied on these declarations, often falling deeply in love or feeling guilty when they did not.

02:08:19 not. They made lifechanging decisions about careers, homes, and families. And then after inflicting an emotional

02:08:31 And then after inflicting an emotional whirlwind for months or years, we have heard that once the UCOs had got what they wanted and the deployments were due to end, they concocted stories of mental breakdown,

02:08:43 breakdown, followed by abrupt disappearance and postcards from overseas. We have also heard that these

02:08:58 We have also heard that these relationships were widely known within the SDS and that the exit strategies were signed off and approved by SDS managers.

02:09:04 managers. Sir, woman after woman has told this inquiry about the havoc these men

02:09:19 inquiry about the havoc these men wreaked with their lives, the confusion, paranoia, and heartbreak, the lost life chances, houses not bought, jobs not taken, children not had. They have spoken of their fears for the health and well-being of a loved man apparently disappeared.

02:09:37 disappeared. of fruitless searches to check they were all right and to set racing minds to rest

02:09:44 rest and of the devastation when their worst fears were realized that the love and sex was based on a lie. They told you of their collapse of trust in the state, in their friends, even in their partners and husbands, of the

02:10:00 their partners and husbands, of the paranoia and paralysis that has gripped them and made daily functioning hard. Many women have told you they feel they have been raped.

02:10:14 have been raped. Sir, that has been tranches one and two. I am now opening for tranch three. And there is more of this. It goes on and on for another 12 years until the SDS was

02:10:28 for another 12 years until the SDS was shut down as surplus to requirements in 2007.

02:10:33 2007. More women tricked into sex and love with newly disturbing features. One UCO attended couples counseling to address his unwillingness to have children. Another continued to pursue

02:10:47 children. Another continued to pursue the women he had abused with sexually explicit messages and requests for suggestive photos and meetings for 16 years after his deployment ended. A

02:11:00 years after his deployment ended. A third UCO married and had children with the woman he had deceived after revealing his true identity. A further UCO proposed marriage in his undercover identity.

02:11:12 undercover identity. What is the same is that more lives were irrevocably damaged. More men were celebrated for deep swimming, a term of art which seems to have meant total immersion into the lives of those spied on. It was

02:11:28 lives of those spied on. It was understood as necessarily including sexual relationships. And there were more senior police officers knowing, encouraging, and facilitating this abuse.

02:11:40 facilitating this abuse. Sir, the evidence of widespread knowledge and indifference at all levels of seniority is even clearer in TR 3.

02:11:53 of seniority is even clearer in TR 3. The SDS's closing report dated 2009, for example, recalls evidence of sexual relationships occurring, but does not consider it worthy of more than a passing remark.

02:12:06 passing remark. The report must have been viewed higher up the chain of seniority.

02:12:19 In TR 3 phase one, we are going to hear from Allison, Ellie, Sara, and Wendy. Later in TR 3 we will hear of other sexual relationships UCOs who deceived

02:12:31 sexual relationships UCOs who deceived Maya Rosa Monica and Ruth Lindsay Donny Donna Mlan and Helen Steel. So I'm going to come to some of the details of what happened to Allison Sara Ellie and Wendy. But first, I want to

02:12:47 Ellie and Wendy. But first, I want to emphasize something important about the S SDS's sexual and romantic deceit. It is a common misconception that a police officer deployed by the state

02:12:58 police officer deployed by the state undercover who deceives a woman into sex

02:13:09 undercover who deceives a woman into sex while deployed does no more or less than the conman or lethario who tricks a woman into a sexual relationship. perhaps after a meeting in the pub or at a party.

02:13:16 a party. Such a man may lie about anything and everything from identity to wealth to intentions. This, the argument goes,

02:13:30 intentions. This, the argument goes, while morally reprehensible, is just the ordinary stuff of life. Women are expected to be wary of such trickery,

02:13:43 expected to be wary of such trickery, and if they fall for it, more fool them. The view that the sexual misconduct of UCOs was equivalent to this and a private moral issue has been expressed by numerous police officers and managers at this inquiry. It was also, it must be

02:14:01 at this inquiry. It was also, it must be said, part of the reasoning of the court of appeal in Monaco and director of public prosecutions. Sir, this is a fundamental misunderstanding. It is wrong and I invite you to say so.

02:14:16 It is wrong and I invite you to say so. It grossly underestimates the gravity of the misconduct and the severity of the damage caused to victims. The state has a special role in all of our lives outside the family. It is the

02:14:36 our lives outside the family. It is the most important feature of our existence. It is the organized part of our society imbued by us with special powers and responsibilities. It devises and implements laws. Since we are a democracy, it tells us it is doing so in our interests.

02:14:47 so in our interests. Those laws form a moral framework for society as well as a pragmatic one. And we agree to comply. In short, we construct our entire lives

02:15:03 In short, we construct our entire lives around the state and we are asked to and do place our trust in it. When agents employed by the state turn out to have used its resources to abuse us, this creates a profound crisis.

02:15:23 us, this creates a profound crisis. The crisis is very bad even if the agent is a rogue because the state should not have allowed such a rogue to operate. It is even worse when the agent is not a rogue but acting with the active or

02:15:34 rogue but acting with the active or tacit approval of some part of the state apparatus. And it is worse still when this goes on

02:15:45 And it is worse still when this goes on for years and is deliberately concealed by the state emerging by accident only decades later. This ruptures our trust in the entire world. It suggests our whole existence

02:15:56 world. It suggests our whole existence has been and could still be based on a lie. And when the abuse is a sexual abuse of a woman's body, an infiltration of a woman's emotional life, the state's

02:16:11 of a woman's emotional life, the state's misconduct contaminates them completely. It invades memories of countless intimate moments and disrupts multiple aspects of the construction of ourselves.

02:16:25 ourselves. This is not just one act of sex or one act of deception, but thousands of memories of intimate moments in hundreds of days trashed. The photograph albums we have in the

02:16:36 The photograph albums we have in the mind are polluted by an intruder and that intruder is the state who we have always been told to trust.

02:16:51 always been told to trust. The painstaking work of reconstructing our memories to represent truth will take a lifetime. Sir, the prof the state's profound

02:17:04 Sir, the prof the state's profound betrayal of the category HCPs and the farreaching damage caused must be properly recognized. And the particular evil of the acts perpetrated by each of these UCOs and

02:17:15 perpetrated by each of these UCOs and their managers and superiors must also be properly acknowledged. I will be asking you to do that in your report on the SDS.

02:17:23 the SDS. I will also be asking you to recommend that in future this conduct is accepted to be a serious sexual offense.

02:17:34 to be a serious sexual offense. As the category HCPs have repeatedly said, sir, this is equivalent to rape with lifelong consequences.

02:17:46 with lifelong consequences. Their experience as victims must be given the weight it deserves. It cannot be right that an ordinary person who impersonates a person's husband or pretends to be a different gender is committing rape. But UCOs who

02:18:05 gender is committing rape. But UCOs who trick their way into women's bodies and the managers who conspire with them to do so are not committing any sexual offense at all. These UCOs are misusing the resources of the state to obtain

02:18:18 the resources of the state to obtain consent to sexual intercourse by deceit. They are doing so as they have all accepted in the clear knowledge that consent would never be given and would be withdrawn if their true identities were known. The violation is so severe

02:18:32 were known. The violation is so severe it amounts to a breach of article 3 of the European Convention on Human Rights. You have seen the damage and degradation it causes. The callous disregard for

02:18:48 it causes. The callous disregard for women which is its cause. It makes no sense at all that this is not also a sexual offense in UK law. Indeed, it is shameful that our domestic law outside the European Convention on Human Rights

02:19:02 the European Convention on Human Rights does not recognize the severity of this conduct.

02:19:06 conduct. Sir, in my closing submissions for trance tranch 3, I will make more detailed submissions on the law on this matter and I will invite you to say in your report on the SDS that this is or

02:19:18 your report on the SDS that this is or should be an aggravated rape and to rec recommend that either Monica and DPP is reconsidered with your findings in mind or that a new statutory offense with a

02:19:33 or that a new statutory offense with a high level of penalty is created which recognize this recognizes this as a sexual offense and acknowledges the special breach of trust and the severe consequences for victims.

02:19:51 consequences for victims. It will be the category HCP's case that our society, our courts, and our state legislation owe this to them to compensate them for the profound failings which have led to their abuse. Our society also owes it to future

02:20:05 Our society also owes it to future generations of women and children so that those responsible are properly punished if this or anything like it ever happens again. I raise this now because I ask you to consider the evidence in tr 3 with this in mind.

02:20:28 Sir, in his written closing for this trunch, the commissioner, sorry, in his written opening for this trunch, the commissioner of Metropolitan Police Service has once again apologized for

02:20:40 Service has once again apologized for the mistreatment of the of women by UCOs and for the failure of managers to prevent it. He has accepted the relationships were abusive, deceitful, manipulative, and wrong. He has also repeated his acceptance that a wider

02:20:55 repeated his acceptance that a wider culture of sexism and misogyny in the in the MPS allowed it to happen. The category HCPs are grateful for this acceptance. They are also glad that the commissioner has acknowledged the

02:21:06 commissioner has acknowledged the strength of the evidence that managers knew what was occurring and they welcome the commissioner's strong condemnation of the attitudes of managers exemplified in the train trade craft manual as

02:21:18 in the train trade craft manual as demonstrating a to quote him complete disregard for the sexual autonomy of the individuals who are being deceived into sexual relationships and the emotional

02:21:32 sexual relationships and the emotional and psychological consequences of that deception on them. As the commissioner recognizes, the

02:21:44 As the commissioner recognizes, the trade craft manual amounted to condoning sexual activity and left UCOs with the impression that sexual relationships were a gray area. That impression has lasted to this day. Time and again, we have heard UCOs seeking to justify or

02:21:59 have heard UCOs seeking to justify or minimize their conduct by reference to the gray area. The commissioner has made three further important admissions which the category HCPS welcome and wish to highlight.

02:22:14 HCPS welcome and wish to highlight. First, he accepts that it is as a result of the efforts of many category HCP women that senior police officers in the MPS and other police services would now be expected to recognize sexual

02:22:26 be expected to recognize sexual misconduct as an abuse of power and to understand the the significant effects that it has on the people who are manipulated and deceived.

02:22:40 manipulated and deceived. Second, he says it is a matter of deep regret that such recognition and understanding was not part of the prevailing culture within the MPS during the 1990s and 2000s.

02:22:52 the 1990s and 2000s. Third, he apologizes for the way in which the MPS responded to the exposure of the sexual relationships to the public and to the civil litigation

02:23:05 public and to the civil litigation brought by many of the category HCPs. He says secrecy and the NCND that is

02:23:21 He says secrecy and the NCND that is neither confirm nor deny principle was wrongly prioritized over openness and cander. And he he apologizes that it took so long to appreciate that the gravity of the misconduct by its officers uh and the way in which those officers had abused the power afforded by them uh uh afforded them by their covert identities.

02:23:37 covert identities. The category HCPS wish to underscore their appreciation of these further admissions. They agree it has taken far too long to reach this point. It is in their view indisputable that the

02:23:51 their view indisputable that the previous leadership of the MPS was responsible for these failings. They note the current commissioner's reference to the MPS playing an active part in the inquiry, meeting some women

02:24:04 part in the inquiry, meeting some women outside the inquiry process and hearing their evidence in the inquiry. So the category HCPs have also played an

02:24:18 So the category HCPs have also played an active role in the inquiry. Many of them have attended every day of evidence. Most have also given evidence even though it has been painful to do so.

02:24:29 though it has been painful to do so. and they have undergone the ordeal of watching the evidence of UCOs and managers.

02:24:33 managers. That evidence has often been deeply duplicitous and contemptuous. It has been marred by repeated failure to show remorse for their sexual misconduct and by attempts to justify it. Some UCOs have pointedly refused to

02:24:50 it. Some UCOs have pointedly refused to align themselves with the commissioner's apology to the category HCPs. The category HCPs have expended this effort and exposed themselves to this further pain because they are profoundly

02:25:05 further pain because they are profoundly committed to the process and regarded as a public service. Sir, I know that all of us who have heard the women speak for themselves describing what it means to be deceived and illreated in this way, the thousands

02:25:24 and illreated in this way, the thousands of degradations large and small which it involves will have been struck by how impossible it is for anyone else to properly describe what has happened to

02:25:38 properly describe what has happened to them or to imagine it. their evidence, the damage that has been done to them and the dignity of their suffering leaves an indelible impression. There is in short no substitute for hearing from the women themselves.

02:25:51 hearing from the women themselves. I would like to extend an invitation on behalf of the category HCPs to the commissioner to meet them for himself so that he can hear from them personally as part of his commitment to ensuring

02:26:05 as part of his commitment to ensuring that whatever rules and guidance are set for the future, it can truly avoid anything like this ever happening again.

02:26:23 I come now to the women whose experiences are to be considered in this first phase of tranch 3. Allison, Sara, Ellie, and Wendy. There is a written opening statement which sets out their experiences in detail.

02:26:31 detail. They have each prepared written statements, and they will each be giving oral evidence. Sara this Friday 17th of

02:26:47 oral evidence. Sara this Friday 17th of October, Wendy and Ellie on Thursday the 23rd of October, Ellie again on Monday the 3rd of November and Allison on Monday the 8th of December. This is therefore only a short outline and I

02:27:01 therefore only a short outline and I want to emphasize again that no summary of what happened to these women can do it justice. It is critical to the to hear from the women themselves and to read their own accounts. First, Allison

02:27:17 First, Allison Allison was deceived by UCO Mark Jenner into an intense 5-year sexual relationship between 1995 to 2000. She knew him as Mark Cassidy.

02:27:30 She knew him as Mark Cassidy. She was 30 when the relationship started and she believed it would lead to long-term partnership and children. In fact, Jenna was already married with children.

02:27:39 children. Jenna moved into the flat she owned and infiltrated every aspect of her personal life. As far as she understood, he was her long-term partner. He behaved as if

02:27:54 her long-term partner. He behaved as if they were settling down for life. He was introduced to her entire family. He attended countless family occasions and went on numerous holidays with her.

02:28:11 went on numerous holidays with her. Allison recorded video footage of their life together. The inquiry is going to show extracts of it. It reveals how extraordinarily domesticated and intimate their relationship was. Watching how Jenna behaved in this way when all along he was a UCO spying on

02:28:26 when all along he was a UCO spying on Allison and her friends and intending to leave her is chilling. There is a particularly egregious example of his emotional abuse of her. Initially, Jenna said he would have children, but he then kept putting it

02:28:38 children, but he then kept putting it off. Eventually, Alson suggested couples counseling. Jenner agreed. Together they attended relate to discuss this. They went on a weekly basis for 18 months.

02:28:51 went on a weekly basis for 18 months. Allison says this was extremely cruel when he already had a family of his own and knew that he would never want to

02:29:04 and knew that he would never want to have children with me. I cannot fathom how Mark was able to continue this sherade for so long. This is an understatement. It requires a cold, calculating mindset to sustain a deception this pervasive.

02:29:19 to sustain a deception this pervasive. Doing so indicates pathological contempt for other human beings. The damage Jenner caused Allison did not stop there. In December 1999, he began his exit strategy, baining mental

02:29:34 his exit strategy, baining mental illness, distress, and depression, and exhibiting erratic behavior. Internal documents disclosed by the MPS show he was quite relaxed and looking forward to the end of his deployment.

02:29:45 forward to the end of his deployment. Then he suddenly disappeared from her life in April 2000, sending a couple of letters and then ceasing conduct contact.

02:29:54 contact. His behavior turned her life upside down. She suffered severe depression and paranoia.

02:30:02 paranoia. She intensively searched for him, initially fearing for his health. Soon, however, she began to suspect he was a

02:30:15 however, she began to suspect he was a spine. Her searches, including hiring a private detective in 2001, bore fruit. By the end of 2001, she had discovered he was using a false identity, but had not discovered who he really was. Few

02:30:30 not discovered who he really was. Few people believed her suspicions and at times she questioned her own sanity. In 2003, she was introduced to Helen Steel. Helen had had a similar

02:30:41 Steel. Helen had had a similar experience with her disappeared partner, John Barker, who was in fact John Dyn. Helen showed Allison material which led her to believe Jenna was a special branch police officer.

02:31:01 branch police officer. It wasn't, however, until 2011 that she had confirmation that Mark Cassidy was Mark Jenner. This occurred after the revelations about Mark Kennedy led Allison to start a civil claim against the Metropolitan Police. Allison was told who Jenner was by a

02:31:13 Allison was told who Jenner was by a journalist in September 2011, and his true identity then entered the public domain.

02:31:20 domain. The police response, by contrast, was for years to neither confirm nor deny Jenna's identity and his status as a

02:31:31 Jenna's identity and his status as a police officer. The MPS was still doing so in response to Allison's court case and when it settled her civil claim and offered her an apology. And as I've said, uh, the MPS have now apologized

02:31:55 said, uh, the MPS have now apologized for forcing Allison and other category HCPS to bring this litigation and for insisting on NCND for so many years. That apology is years too late, but welcome.

02:31:57 welcome. Allison has suffered immeasurably from her mistreatment. As she explains in her statement, Jenna's actions caused her to withdraw from politics and campaigning and have had ongoing impacts on her

02:32:15 and have had ongoing impacts on her marriage. She considers that the actions of Jenna and the SDS in tricking her into sex amount to rape. But Allison has been steadfastly at this inquiry despite this pain for weeks of evidence, supporting other women,

02:32:27 evidence, supporting other women, enduring the evidence of police officers who seem largely unrepentant. And on the 8th of December, she will give evidence

02:32:38 8th of December, she will give evidence herself. She has performed a true public service.

02:32:40 service. The same cannot be said of Jenna. His

02:32:51 The same cannot be said of Jenna. His witness statement shows a startling lack of remorse or empathy. It is clear from his evidence that Jenner views himself as the true victim. He shows scant regard not only for Allison but also for his former wife s was herself wrongly sorely wronged by

02:33:10 was herself wrongly sorely wronged by Jenna and the SDS. She is also due to give evidence on the 9th of December 2025.

02:33:17 2025. Jenna's oral evidence will be heard for 4 days from the 15th to the 18th of December.

02:33:20 December. I come now to Sara. Sara is one of two women tricked into sexual relationships by James Tom Thompson.

02:33:30 Thompson. The other woman is Ellie. A third, Wendy, was tricked into a long-term friendship from the age of 17. Wendy believes that Thompson had a sexual interest in her.

02:33:46 sexual interest in her. Thompson was a rogue officer, even by the SDS's lack Sanders, as I will explain. But first, I want to address his relationships with the three women. Sara met Thompson in autumn of 1998.

02:34:00 Sara met Thompson in autumn of 1998. She had just started going on Hunt SAS after developing an interest in animal welfare.

02:34:09 welfare. The relationship became sexual after a few months and quickly a serious and intense relationship. Sara fell for James and adored him. Had

02:34:24 Sara fell for James and adored him. Had he asked, she would have married him. He told her he loved her in around the summer of 1999. Over Christmas 1999, Sarah didn't hear from Thompson for around 2 weeks, causing her alarm and upset. After she

02:34:38 causing her alarm and upset. After she emailed him, he turned up at her house with a letter. He told her he was a

02:34:50 with a letter. He told her he was a survivor of serious childhood sexual abuse and that he struggled to form long-term intimate relationships. He said that he started a sexual relationship with Sara because he wanted to be close to her and it would have been odd if he had not. He said it was not fair on Sara to continue the sexual

02:35:07 not fair on Sara to continue the sexual relationship, but he wanted to continue to spend time with her and to be friends.

02:35:14 friends. Thereafter, Thompson and Sara continued a platonic but emotionally intimate relationship.

02:35:25 relationship. This continuing closeness caused Zara to hope that he would change his mind with time or that we could somehow work it out, as she put it. When she asked Thompson how he would feel if she started a relationship with someone else, he said he would not have liked it.

02:35:36 liked it. She retained a hope that the sexual relationship could be rekindled, but she gradually lost that hope as time went on.

02:35:46 on. In the summer of 2000, Sarah started a casual relationship with another man ex about which she felt guilty because of what Thompson had said to her. In March

02:36:05 what Thompson had said to her. In March 2001, Sara left the UK to move abroad. A few weeks after Sara left, Thompson began his relationship with Ellie. Sara says, "I went through every emotion

02:36:16 Sara says, "I went through every emotion and also disbelief. I was shocked, hurt, angry, confused, and so upset. My self-esteem plummeted. I had a hollow

02:36:28 self-esteem plummeted. I had a hollow feeling of rejection. I felt screwed up over it all. Was it just me that he didn't want to have a physical connection with? Had I done something wrong? Did I imagine his feelings for me? Was he honest about the sex part? I

02:36:41 me? Was he honest about the sex part? I felt crushed by it. I was also concerned about what he was doing to Ellie. So much so that I felt physically sick. He was leading her up the same path he led me. I thought about it a lot and it impacted on my sleep.

02:36:55 impacted on my sleep. Thompson never replied to her emails asking why he began a relationship with Ellie. She never heard from him again. And his actions haunted her. She could

02:37:10 And his actions haunted her. She could never really put it to rest because what had happened did not make sense to her. There was a sense of unfinished business, guilt, and confusion.

02:37:21 The inquiry informed Sara in August 2018 that Thompson had been a UC. This caused her to feel deep betrayal, shock, and anger. She has felt unsafe

02:37:33 shock, and anger. She has felt unsafe and like she might be under scrutiny. She has felt like her life was being invaded again and again and again. She cannot grieve for the relationship as she had believed it to be. How do you

02:37:46 she had believed it to be. How do you grieve for something that is not real? She asks.

02:37:52 She asks. Learning Thompson's true identity has had a huge impact on Sara. She feels paranoid and she is exhausted as a result of the emotional stress. She

02:38:03 result of the emotional stress. She cannot concentrate and her business has been affected. She wonders if it may have impacted on her marriage. The inquiry itself has been physically and mentally draining. As Sara explains, the

02:38:17 mentally draining. As Sara explains, the pain of this discovery has become deeper and more distressing as the seriousness of the violation and the extent of the betrayal and the complete invasion of my privacy sinks in. Now I feel like my

02:38:30 privacy sinks in. Now I feel like my life is being invaded again and again and again. I feel devastated, sick, angry, and disgusted about being deceived, used, and violated in this way.

02:38:41 Ellie. Ellie was deceived into an intimate sexual relationship by Thompson in 2001 when she was 21 years old. She was a

02:38:58 when she was 21 years old. She was a particularly young and naive 21-year-old and Thompson, who was then 38, was her first serious relationship. Ellie was not an animal rights activist and had very limited involvement in animal rights.

02:39:12 animal rights. She first met Thompson in 1999 or 2000 while volunteering at a wildlife hospital with Wendy with whom she lived and was friends. In the year 2000, when Wendy's mother was terminally ill, Ellie observed

02:39:30 was terminally ill, Ellie observed Thompson being helpful to Wendy and came to learn that he had recently been separated from Sara. At this time, Ellie was in a vulnerable position. She was being sexually harassed and threatened by a senior

02:39:43 harassed and threatened by a senior colleague. The harassment was wearing Ellie down and left her exhausted. Eventually, Wendy invited Ellie along

02:39:54 Eventually, Wendy invited Ellie along with Ellie's sister to live with her and she secured a stable job. Around this time, Thompson asked Wendy whether she would set him up with Ellie, which she did. Ellie agreed to meet

02:40:06 which she did. Ellie agreed to meet Thompson, liked him straight away, and an intimate relationship quickly began. They would go out for dinner and take day trips. Thompson would be romantic

02:40:21 day trips. Thompson would be romantic and send postcards. He once took Ellie to look around a school from which he told her he had been expelled. Ellie recalls Thompson declining to have sex until she received a contraceptive injection and never wearing a condom.

02:40:33 injection and never wearing a condom. There was a significant age gap between them given Ellie's young age. She was 21 and particularly young and naive and also in a mess as a result of the

02:40:49 also in a mess as a result of the difficulties she had faced in her life. In around January 2002, Thompson told Ellie he might have to go and live in America to be nearer his children. In

02:41:01 America to be nearer his children. In around February, he said he would need to need to leave for the US very soon and appeared to disappear, leaving Ellie

02:41:18 and appeared to disappear, leaving Ellie with the gift of a motorbike horse and a romantic card, which hinted that they might go on a trip together again. Ellie was really devastated and heartbroken by Thompson leaving. However, Thompson remained in touch and continued to string Ellie along. Not

02:41:32 continued to string Ellie along. Not long after he left, he sent her an email suggesting they meet up. As she explains, "Our relationship as it was

02:41:43 explains, "Our relationship as it was had come to an end, but some other kind of relationship picked up in its place that was much more of a more than a friendship as it was intimate, loving, and romantic in nature. And there was

02:41:55 and romantic in nature. And there was always sexual attraction and intimacy in our interactions, whether in person, on the phone, or in correspondence. Every time we met, it was like being on a date. Every time we parted in person, we kissed like a couple.

02:42:10 we kissed like a couple. Thompson and Ellie would email every few months, and the emails were often romantic and sexual in nature. She had no serious romantic interactions with

02:42:26 no serious romantic interactions with anyone else for 2 years after he left. In 2005, Wendy and Ellie left for Australia. But Ellie and Thompson remained in email contact with Thompson continuing to express romantic interest and repeatedly requesting intimate photographs

02:42:39 requesting intimate photographs along with sexually suggestive comments. The two continued to meet every so often and would always have an intimate

02:42:53 and would always have an intimate goodbye kiss. On one occasion in 2015, Thompson and Ellie had sex again. In 2017, while the inquiry was ongoing

02:43:06 In 2017, while the inquiry was ongoing and Thompson must have known that Ellie would learn of his deception, he asked for her address in Australia. she gave it to him. But despite this, he lied to the inquiry when asked if he could assist in locating her.

02:43:17 could assist in locating her. In April 2018, Thompson confessed to

02:43:30 In April 2018, Thompson confessed to Ellie that he had been a UCO. He did not apologize, but claimed that despite the deception, he had always respected Ellie.

02:43:37 Ellie. The impact of the deception on her has been immense. It left her with a deep mistrust of those who she previously believed were there to protect society as a whole. She still has not been able to fully process what happened or to

02:43:50 to fully process what happened or to come to terms with who the real Thompson is. She now feels unsafe because he had her address and because his job appears to involve him associating with armed men. She feels constantly anxious that

02:44:09 men. She feels constantly anxious that she's under surveillance. She says this, "I despise being some sort of victim. I hate that I was gullible and so naive, but seeing what the Metropolitan Police are like nowadays, I am no longer surprised that they never even

02:44:22 surprised that they never even considered we were worth basic respect. I hate the amount of tears I've shed over this as it makes me feel pathetic. I feel angry that he did all this to me with no concern for my sexual, physical, or mental health, and that the police

02:44:36 or mental health, and that the police supported him to do it and even paid him very well for it. Thompson's ongoing contact made it very difficult for Ellie to move on from their relationship, and she thinks a lot now about how long Thompson would have

02:44:48 now about how long Thompson would have continued to string her along had he not

02:45:00 continued to string her along had he not been revealed. She has become suspicious of everyone. She's now alone and cannot see that changing. She can never trust trust another man again.

02:45:08 Sir Wendy. Wendy was deceived into a long-term friendship with Thompson for 21 years from 1997 until 2018. She was

02:45:19 21 years from 1997 until 2018. She was only 17 when Thompson befriended her. By then she had been in engaged in animal advocacy from the age of 14 and had just started hunting. After meeting Thompson they became

02:45:35 After meeting Thompson they became extremely close and as I mentioned Wendy has always suspected that he had a romantic interest in her. Wendy's mother was terminally ill from 2000 and died in early 2001.

02:45:51 2000 and died in early 2001. At this time, Thompson put himself firmly within her inner circle of support. He would drive Wendy to hospital. He even met Wendy's mother in

02:46:03 hospital. He even met Wendy's mother in her mother's home. As Wendy points out, at any time he could and should have stepped back and allowed my genuine friends to care for me and offer genuine support when I was losing and had lost the person closest to me in this world at an extremely young age.

02:46:18 at an extremely young age. After Wendy's mother died, she received an inheritance and bought out with it. Internal MPS documents now suggest that the police sought in some way to disrupt this process.

02:46:31 this process. Wendy has explained that this caused me massive stress at the worst time in my life. And when she recently read of of the uh police's attempt to interfere in

02:46:42 the uh police's attempt to interfere in her life in this way, the impact on her cannot be overstated. Uh it wasn't just um Ellie that Thompson maintained contact with after their move

02:46:56 maintained contact with after their move to Australia in 2005. He also maintained that contact with Wendy um with email phone calls and also arranging to meet. Over this period, which was after his

02:47:09 Over this period, which was after his STS deployment had ended, but while he was still working for the police, Thompson would regularly ask for information about others they had known in the animal rights movement. Wendy says that she considered him a long-standing close friend over this

02:47:22 long-standing close friend over this period of time, but now she feels he was keeping contact partly to play God and partly because I could be useful for him as he knew I was still working on animal issues and in contact with other activists.

02:47:37 activists. Wendy found out that Thompson was a UCO from Ellie in 2018. Although Ellie had although Thompson had told Ellie not to tell her, the impact on her has been substantial. She cannot trust anyone

02:47:50 substantial. She cannot trust anyone anymore. She feels unsafe, including from the state. She has isolated herself from the animal animal rights movement, a core part of who she is, and stepped

02:48:05 a core part of who she is, and stepped back from media roles because she feels it's safer for her. The discovery has therefore affected with her affect interfered with her professional choices and she has found it difficult to come to terms with the fact that I was manipulated by Thompson for over two

02:48:25 manipulated by Thompson for over two decades including as a vessel through which he targeted potential sexual partners. That's her evidence. Realizing that he met her mother while she was dying and the guilt of having brought him into Ellie's life have

02:48:36 brought him into Ellie's life have caused Wendy's symptoms of physical illness, including nausea and extreme fatigue. Her last memories with her

02:48:48 fatigue. Her last memories with her mother are forever tainted. She feels violated, degraded, and dehumanized.

02:48:56 So that that those are the accounts of the four women um whose evidence is are

02:49:09 the four women um whose evidence is are going to be heard uh in this uh uh first phase of tranch 3. I want to address shortly some um key features of the officer Thompson who deceived all all three of the last uh uh three women that I've spoken of.

02:49:22 uh uh three women that I've spoken of. That's Wendy, Sara, and Ellie. Thompson is an officer whose tenure in the SDS was considered scandalous, even by SDS standards, although not because of his sexual relationships.

02:49:34 sexual relationships. He receives specific mention in the SDS's closing report, which was years after his deployment had ended. That

02:49:45 after his deployment had ended. That report was produced in 2009 and he has been the subject of numerous critical internal police reports. Those reports record a catalog of misconduct, lies, and potential criminal offenses. And

02:50:00 and potential criminal offenses. And they include the overall assessment that his operation in the SDS was a sham and that he fabricated an entire operation,

02:50:14 that he fabricated an entire operation, Operation Lime, so as to fund a trip to France and extend his deployment. Strikingly absent from all this criticism, however, is any concern or care for the women he abused or any attempt to protect them after his deployment ended.

02:50:26 deployment ended. Many others will be addressing Thompson's conduct because the failure to properly discipline him is a sign of just how lawless the STS became. The doctrine of protecting the SDS at all

02:50:42 doctrine of protecting the SDS at all costs meant that there were in practice no enforcable rules for UCOs and Thompson's case demonstrates this. But for the category HCPs, the situation is far worse. Thompson's mistreatment of

02:50:55 far worse. Thompson's mistreatment of men was not even thought necessary to correct, so that it barely warrants a mention in the SDS's closing report. It is a sign of how big a problem

02:51:11 It is a sign of how big a problem misogyny is for the SDS and the MPS that the sexual abuse of women was thought necessary and incidental to undercover work by so many police officers at all levels of seniority.

02:51:25 levels of seniority. Peter Francis in his evidence to be heard in tranch 3 says that sexual relationships were an ordinary part of the undercover role regarded by officers and management alike as part of the work. Most UCOs were engaging it. He

02:51:43 work. Most UCOs were engaging it. He says his evidence on this is obviously true.

02:51:49 true. Sexual relationships were synonymous with and necessary too, the deep swimming approach to undercover deployments that was so celebrated by Bob Lambert and the SDS, including SDS management.

02:52:03 management. As recently as 2012, MPS Commissioner Bernard Ho Hogan How was describing sexual relationships as inevitable. And many of those giving evidence in this inquiry in 2023 to 2025

02:52:14 inquiry in 2023 to 2025 still appear to believe this. They regard the commissioner's apology for it as unrealistic and even disgraceful. The closing report, the SDS's closing

02:52:29 The closing report, the SDS's closing report shows that misleading the courts was deemed far more scandalous. Sir, the category HCPs agree that police officers misleading the courts is a scandal. But as far as the public and

02:52:42 scandal. But as far as the public and this inquiry is concerned, the sexual abuse of women by UCOs is accepted to be far more invasive of the most basic human rights of individuals than

02:52:53 human rights of individuals than misleading the courts. That it was not seen this way at the time by the police or it seems the home office or the security service is indicative of a

02:53:10 security service is indicative of a deeply problematic culture of contempt for women. That many policemen giving evidence to you still seem to think sexual relationships were justified is of the utmost concern. I started my opening today, sir, with an

02:53:23 I started my opening today, sir, with an invitation to you to recommend that this abuse of women be recognized as a serious sexual offense. The attitudes that we have seen in the first two tranches and are seeing more of in this

02:53:36 tranches and are seeing more of in this branch show how badly this is needed. It is needed to properly reflect the intense moral approprium with which the

02:53:48 intense moral approprium with which the general public views the conduct of the SDS in deceiving women members of the public into intimate sexual relationships. It is needed to ensure the police and others start to treat women with the

02:54:00 others start to treat women with the respect they deserve. It is needed to change the culture which led to this abuse.

02:54:06 Sir, in this written in their written opening, the category HCPs have indicated issues of and areas of evidence which they ask the inquiry to explore. I am not going to rehearse them

02:54:17 explore. I am not going to rehearse them in this oral opening, but I do draw your attention to the need to explore why the many legislative developments in this era, particularly the regulation of

02:54:31 era, particularly the regulation of investigatory powers act 2000, which was designed for just this kind of deployment, did not lead to any improvements in the way the SDS operated.

02:54:42 operated. And I do suggest that the failure of regulation to secure safety for the general public is another reason why a criminal offense is needed. So those are my oral submissions.

02:54:59 So those are my oral submissions. Thank you very much and thank you for completing them well within the time that you agreed to do so. May I make two observations to you uh and to those of

02:55:11 observations to you uh and to those of whom you represent uh about what you've said. First and generally, I um am deeply grateful to the women concerned for the witness statements that they

02:55:22 for the witness statements that they have provided with such frankness and depth and for their willingness to give oral evidence which bring all these matters to life in a way that the written word alone cannot do. I will

02:55:40 written word alone cannot do. I will express my gratitude to them personally when they give evidence but I wish at this stage through you to make it clear that uh I that is the position from

02:55:52 that uh I that is the position from which I start and which I anticipate I will conclude. The second thing is is this and I'm afraid is um uh perhaps um uh less uh

02:56:04 afraid is um uh perhaps um uh less uh welcome. uh the submission that I should make recommendations uh about uh a change to uh essentially the law of rape

02:56:17 the law of rape uh is one that I believe goes beyond uh the terms of reference with which I am

02:56:28 the terms of reference with which I am charged and furthermore would require uh a great deal of evidence from fields well outside undercover policing. uh where the impact of such a change might uh work and consequently I am at the moment very doubtful about uh uh

02:56:43 the moment very doubtful about uh uh accepting the invitation that you have indicated that you make. I think we both need to reflect upon it.

02:56:56 I will do so. I will look at the terms of reference and I will address you further on it. Thank you. In due course. very grateful to you as always. Thank you very much indeed. Thank you.

02:57:11 Thank you. If Mr. McCullik is king's council is ready uh then I can hear his opening on behalf of S. I am here and I am ready. Good. Uh I'm very grateful to you uh for being ready to start a few minutes

02:57:24 being ready to start a few minutes early. It will assist our task later on in the day. Thank you. I'm still together with Helen Law, Stephano Ruiz, and Katherine Sora, I represent S, the

02:57:38 and Katherine Sora, I represent S, the remaining member of the category M core participants. Which category, as you know, sir, constituted ex-wives of undercover police officers? Five years ago, through their first

02:57:50 Five years ago, through their first opening statement, the inquiry heard for the first time from some of the ex-wives of former undercover officers. And by that means the ex-wives

02:58:02 And by that means the ex-wives summarized their experiences, their knowledge, and their beliefs about what

02:58:17 knowledge, and their beliefs about what their ex-husbands had done and what they had been permitted and encouraged to do by the other officers around them and above them. The evidence that the inquiry has heard so far has in many respects borne out those beliefs and in some significant

02:58:33 those beliefs and in some significant respects has gone beyond even their very worst fears. On behalf of S, we will use this opening to highlight some of these points which

02:58:45 to highlight some of these points which she trusts will be borne in mind as the inquiry proceeds with this next phase based on those aspects of the evidence that have been provided to her thus far.

02:58:58 that have been provided to her thus far. But some of the evidence, in particular, details of the undercover officer's accounts has also started to jar against Ess's own direct knowledge of how the SDS operated.

02:59:09 SDS operated. Some of the justifications and explanations that are being put forward for how the sexual relationships with targets came to happen because of the vulnerable and isolated position the

02:59:23 vulnerable and isolated position the UCOs were put in do not ring entirely true for S. suggestions that the undercover officers were consistently isolated from their families or lacked sufficiently regular contact with their supervisors

02:59:38 contact with their supervisors are simply not borne out by her experience. Again, she will highlight some of aspects of this in this opening to bring to life what it is she hopes her

02:59:49 to life what it is she hopes her experiences will contribute to the issues the inquiry has to decide in this next phase. And then finally, we will use this

03:00:08 And then finally, we will use this opening to reiterate what s continues to want and indeed need from this process. But before I turn to those issues, a little about S herself and how she finds herself here.

03:00:24 herself here. Before her ex-husband Mark Jenner joined the SDS, S was in a happy and stable marriage with him. They had young children and were living in a home that she loved. Her husband, a special branch officer, told her that he had been

03:00:39 officer, told her that he had been approached to take on undercover work. S knew the role was important to her husband and wanted to support him in his career.

03:00:52 career. His manager, Bob Lambert, came to their home to talk to the couple about the realities of undercover life. He assured S that the welfare of her husband and his entire family was of prime importance to the SDS.

03:01:05 prime importance to the SDS. S felt she could trust Bob Lambert, not only because he was a police officer in a position of trust, but also because her husband had told her that Bob

03:01:16 her husband had told her that Bob Lambert had received a commendation after his own undercover deployment and that his work had prevented bombings. S was also told that Bob Lambert had

03:01:30 S was also told that Bob Lambert had experienced a family tragedy and placed particular importance on family life. She was led to believe that her husband would be involved in dangerous and important work.

03:01:45 important work. work that was legitimized by the most senior members of the Metropolitan

03:01:58 senior members of the Metropolitan Police and helped to ensure the safety of all of us of society as a whole. She offered her husband unwavering support over the course of his deployment. Despite the personal sacrifices to her of keeping secrets from her close friends and family and

03:02:13 from her close friends and family and the responsibility of acting as primary caregiver for her young children over weekends and holidays, her support was so unwavering that when her ex-husband's identity was almost

03:02:25 her ex-husband's identity was almost uncovered by a target walking past him at their family home, she agreed to relocate her young family to a new and unfamiliar area outside of London.

03:02:38 unfamiliar area outside of London. At the time, she was given to understand that her husband was at risk of serious violence if the move did not take place. The seriousness of the threat was

03:02:51 The seriousness of the threat was authoritatively confirmed to her when Bob Lambert attended Ess's home to discuss the moving process and the police paid for their moving costs and associated legal fees.

03:03:05 associated legal fees. Now that S has a better understanding of the types of groups her husband infiltrated, she questions the real reason for the move. She fears that the uprooting of her life and family was

03:03:17 uprooting of her life and family was motivated solely by a concern to ensure

03:03:29 motivated solely by a concern to ensure the continuity of the SDS operation and that she was misled by her husband and Bob Lambert as to the threat that she and her family were under.

03:03:36 s witnessed the profound impact of deployment on her ex-husband and the effect this had on their marriage and their young family.

03:03:49 their young family. Whilst the marriage survived the ups and downs of deployment and many years together subsequently, their relationship ultimately broke down and the couple separated. s only learned of the sexual relationship her ex-husband had when

03:04:05 relationship her ex-husband had when news of it was published in the media many years later. She and her family were blindsided and devastated by the revelation

03:04:16 devastated by the revelation and she struggled to come to terms with the truth. She spent several painful years seeking out information from her husband, trying

03:04:27 out information from her husband, trying to understand what was true and what was not.

03:04:37 not. The police's harmful neither confirm nor deny NCND policy only prolonged the deceit.

03:04:39 deceit. It was only through the hard work and tenacity of so many of the category H core participants on whose behalf you have just heard, sir, that s came to terms with the

03:04:52 sir, that s came to terms with the reality of her husband's deception. The evidence emerging from the inquiry has forced her to reassess every detail of her married life, reinterpreting

03:05:07 of her married life, reinterpreting those details with the knowledge she now has.

03:05:15 has. To give just one example, she recalls her ex-husband taking multiple trips abroad during his deployment. She now understands that these were trips with the woman with whom he was having a sexual relationship.

03:05:26 having a sexual relationship. Her husband paid for these trips personally from their family money and used his annual leave allowance for them.

03:05:41 them. All this took place whilst s remained at home with their young children. From what she has seen, it is inconceivable to her that his manager did not know who he was going with or what was taking place.

03:05:53 what was taking place. So sir, today s continues to seek to engage with the inquiry with a sense of duty.

03:06:00 duty. She has been appalled and horrified by what she has learned so far and wishes to help the inquiry to establish the true nature of how the SDS and its

03:06:11 true nature of how the SDS and its undercover officers operated with the benefit of her unique perspective among all the witnesses that the inquiry will hear from.

03:06:30 hear from. So I turn briefly to the evidence so far and the manner in which it confirms her beliefs and indeed exceeds the fears that she had before the inquiry started.

03:06:42 that she had before the inquiry started. She came to the inquiry seeking answers. She hoped that the inquiry would shed light on aspects of her ex-hus ex-husband's recruitment and deployment that had been hidden from her view. Over the last 5 years, she has been

03:06:54 Over the last 5 years, she has been shocked at some of the answers uncovered which are relevant to the assessments of the issues to be considered in this next phase of the inquiry.

03:07:09 phase of the inquiry. first that the SDS knew by 1993 that its policy of intentionally recruiting married officers wasn't achieving the objectives that they had apparently hoped for. That is of officers having

03:07:23 hoped for. That is of officers having anchors and to deter them from having sexual relationships. By 1993, countless undercover officers had engaged in sexual affairs whilst

03:07:35 had engaged in sexual affairs whilst deployed, and many had suffered mental health issues and breakdowns. So s asks, why did the MPS continue to

03:07:50 So s asks, why did the MPS continue to follow this clearly ineffective policy of recruiting married officers? Second,

03:07:56 Second, although the evidence suggests that the SDS visits to the officers families at the recruitment stage was intended to assess their suitability as undercover officers. There is no evidence, as far

03:08:09 officers. There is no evidence, as far as S is aware, of a single officer not being recruited after these visits. Undercover officers and managers have unsurprisingly commented that a single

03:08:20 unsurprisingly commented that a single visit was insufficient to make any real assessment.

03:08:32 assessment. Such visits could not have achieved the purpose claimed for them and that must have been obvious to the SDS. Third, and relatedly, S is not aware of a single piece of evidence to suggest that anyone within

03:08:46 evidence to suggest that anyone within the SDS or the wider Metropolitan Police considered at the time or indeed for many years after how undercover deployment would impact on the spouses

03:08:59 deployment would impact on the spouses and children of the officers undercover, let alone taking any steps to mitigate those impacts. All the asurances of welfare and support were empty words. And in Ess's case, the only support

03:09:14 And in Ess's case, the only support offered to her was the installation of a panic alarm after her husband's conduct was made public.

03:09:23 Fourth, and again relatedly, undercover officers have almost unanimously reported the detrimental impact of deployment on their welfare and mental health.

03:09:33 health. Officers in triage three are to give evidence that deployment changed their personalities,

03:09:44 personalities, making them, to quote short-tempered and aggressive, and another resultant with resultant paranoia and anger. one developed PTSD and another may have suffered dissociative identity disorder whilst deployed.

03:10:00 whilst deployed. Yet SDS management repeatedly ignored these impacts or failed to make any meaningful changes. However, the single most upsetting revelation that S has learned through

03:10:12 revelation that S has learned through the inquiry is the fact that the SDS was well aware by 1994, which was the date

03:10:23 well aware by 1994, which was the date her ex-husband was deployed, of the risk and the fact of undercover officers engaging in sexual relationships. But no one bothered to tell her or indeed any other spouse, as far as she is aware.

03:10:38 Whilst managers and undercover officers can't agree on whether the specific sexual relationships were hidden by undercover officers, brushed under the carpet by management, or actively encouraged by the SDS.

03:10:50 encouraged by the SDS. The evidence unequivocally shows that any honest manager would have been aware of the risk of such relationships developing.

03:11:09 developing. The disclosure so far shows first that Peter Francis worked on his backstory with SDS management and was very truthful and upfront that sex might have to be involved. On his statement, he recalls that

03:11:21 On his statement, he recalls that non-committal sex was sanctioned and accepted as part of my role. HN67 and Bob Lambert both advised him to carry condoms during his deployment.

03:11:33 carry condoms during his deployment. But this is not just the uncorroborated evidence from Peter Francis. We also note that Mark Jenner was advised by Andy Kohl's that sexual relationships whilst deployed were inevitable as Jenner would struggle to

03:11:50 inevitable as Jenner would struggle to reject advances indefinitely and avoid being targeted by women. Whilst Jenna says that he did not consider this would happen to him, so did not dwell on it, he began his

03:12:02 did not dwell on it, he began his relationship with Allison shortly after meeting her in April 1995, less than three months into his deployment.

03:12:15 Furthermore, HN82 recalls that whilst working in the back office before his deployment, Peter Francis said he told female activists they had to sleep with him if they shared accommodation with him during trips outside of London.

03:12:42 The evidence from the officers that will be heard in triage 3, if accepted, would establish that any plea of ignorance by SDS management would be disingenuous. Peter Francis says he would be very surprised if the whole of the SDS did not know that nearly every SDS officer was having sex whilst undercover.

03:12:54 was having sex whilst undercover. Mark Jenner describes his assumption at the time was that as management knew he was living in the same premises as Allison, the inference was that they were in a relationship.

03:13:06 were in a relationship. Bob Lambert sent other undercover officers to talk to Mark Jenner after he moved in with Allison in mid 1995

03:13:17 moved in with Allison in mid 1995 to ensure that Jenner, in his words, knew what he was doing. Bob Lambert also authorized Mark Jenner to take two overnight trips out of London purportedly to attend meetings

03:13:35 London purportedly to attend meetings with the Colin Roach Center. These trips took place over New Year's Eve 1996 and Valentine's Day 1997. As a manager with experience of being deployed in the field, Bob Lambert does not appear to have considered it odd that the Colin Roach Center, a

03:13:48 that the Colin Roach Center, a Hacknebased organization, was holding meetings in North Umbrea and Bristol on New Year's Eve and Valentine's Day.

03:14:02 New Year's Eve and Valentine's Day. Bob Lambert re-entered the SDS in the tri period, taking up his management role. S has yet to be provided with Lambert's evidence, but she will find any attempt by Lambert to deny knowledge of undercover officers sex relationships

03:14:21 of undercover officers sex relationships to be remarkable given the prevalence of sexual misconduct throughout his own deployment. And finally, in these examples that we highlight, James Thompson uh considered that his managers would not approve of his deceptive

03:14:33 not approve of his deceptive relationship with Sarah and Ellie because it was more deeply felt and referred to in the guidance, which is a as we understand it a reference to the trade craft manual. And this clearly tends to indicate that shallow

03:14:48 tends to indicate that shallow relationships, shallow and inverted commas were considered acceptable. What is perhaps unique to the triage 3 period is that undercover officers

03:15:07 period is that undercover officers repeatedly continued to engage in these deceptive and abusive relationships after their deployments had ended. Despite Andy Cole's advice in the tradecraftraft manual that sector relationships should be fleeting and disastrous, many undercover officers deployed in TR 3 appear to have engaged

03:15:23 deployed in TR 3 appear to have engaged in serious and long-term relationships. They moved in together, spent Christmases together, and took holidays together.

03:15:29 together. The notion that women like S were capable of providing stability and anchor for their undercover husbands

03:15:43 anchor for their undercover husbands against that background is considered by her to be as derisory as it is contemptable.

03:15:50 I next turn to the unique perspective that s offers to this inquiry. She has previously told the inquiry of that unique perspective on the SDS. As

03:16:03 that unique perspective on the SDS. As the wife of an undercover officer, she had an intimate view of the realities and impact of deployment on her officer husband and her own family. No one else can offer that perspective.

03:16:17 can offer that perspective. The value of her evidence is demonstrated by her witness statement, which provides an alternative perspective to the narrative rehearsed by many officers. For example, the inquiry has repeatedly

03:16:30 For example, the inquiry has repeatedly heard evidence from undercover officers that they spent almost all of their time in their cover identity, that deployment required undercover officers to spend

03:16:43 required undercover officers to spend extended periods of time away from the family home and that they were effectively isolated from their families and support networks. Just to highlight three examples of these suggestions from undercover

03:16:58 these suggestions from undercover officers. Peter Francis uh says that during his deployment he would ordinarily spend five to six days per week including nights in his assumed identity.

03:17:07 identity. uh and we've in our written opening uh have uh included a fuller quotation and

03:17:20 have uh included a fuller quotation and reference similarly from Andy Kohl's who refers to spending working spending six days a week working and most weekends and on working days spending 12 to 16

03:17:35 and on working days spending 12 to 16 hours in his cover identity and likewise Trevor Morris's estimates of 85% of his time in his assumed identity. However,

03:17:37 However, by contrast with these suggestions, S recalls that her ex-husband was around every weekday from early morning to around 5 or 6:00 p.m.

03:17:52 around 5 or 6:00 p.m. He looked after their children and spent a good amount of time with their young family over his deployment. Her then husband was away at weekends and evenings, but he was physically present for much of the time. Her

03:18:05 present for much of the time. Her evidence appears to be consistent with that of HN20, who describes a general pattern in line

03:18:18 who describes a general pattern in line with that provided by S, which we quoted and referenced in our written opening. The inquiry has also heard undercover officers give evidence that they worked in isolation with little support or supervision from senior management. Likewise, managers have relied on the

03:18:29 Likewise, managers have relied on the isolated nature of undercover work to justify their apparent ignorance to the sexual relationships taking place under their noses.

03:18:42 their noses. However, again, S recalls it differently. She recalls that her ex-husband was closely supervised and on the phone daily with his managers, primarily Bob Lambert.

03:18:53 Lambert. She also recalls that her then husband attended twice weekly meetings with his team and had a close group of SDS friends. She herself attended multiple

03:19:05 friends. She herself attended multiple SDS Christmas parties where she met her husband's colleagues and their wives and partners.

03:19:12 partners. During these parties, managers and senior managers would thank S for her sacrifice and emphasize to her the

03:19:23 sacrifice and emphasize to her the importance and value of her husband's work.

03:19:30 work. S now knows that some of the men she met during these events knew of her husband's infidelity, but they never chose to share that information with her. S also provides a unique perspective on

03:19:44 S also provides a unique perspective on the culture of secrecy and fear fostered by the SDS operation. In tranch 2, we heard from Trevor Morris who explained that he feared seeking help from medical professionals for fear of breaching the official secrets act.

03:20:01 of breaching the official secrets act. s similarly felt the secrecy of the SDS was given paramount importance even after the details of her husband's betrayal was being reported in the media and announced in parliament. She felt

03:20:15 and announced in parliament. She felt unable to seek out support or help for fear of her own safety. She now describes feeling as though she was brainwashed by this culture secrecy.

03:20:32 So in the last section I turn to the question what does s hope hopeful from this tranch and from the inquiry she has noted and appreciates the apology provided to her and other ex-wives of undercover officers

03:20:57 ex-wives of undercover officers including as reiterated in Mr. Skelton's opening on behalf of the MPS yesterday. She acknowledges and accepts that as a genuine apology provided by the commissioner. However, she hopes that the genuiness of

03:21:09 However, she hopes that the genuiness of that apology is matched by cander in the evidence of officers giving evidence. In that regard, she has been disappointed by what seems to her to be a tight-lipped approach taken by so many witnesses from the SDS.

03:21:20 witnesses from the SDS. She asks and hopes that the former undercover officers and SDS managers giving evidence in this coming trunch should approach their evidence with the

03:21:34 should approach their evidence with the same sense of commitment as they gave to their undercover work. The SDS justified its behavior by claiming it was to protect the greater good and she hopes that the same individuals will consider the greater

03:21:48 individuals will consider the greater good when responding to questioning by council to the inquiry. This inquiry has been set up for a purpose and what may be characterized as

03:22:00 purpose and what may be characterized as an obstructive approach taken by so many witnesses inhibits that purpose from being achieved. She considers that the lack of transparency that she has seen so far is disrespectful

03:22:14 so far is disrespectful to all those other witnesses who are candidly engaging with the inquiry, sometimes at immense personal cost. In giving her evidence, s must also

03:22:26 In giving her evidence, s must also consider the welfare of her children and wider family who have also been profoundly impacted by her ex-husband's deployment.

03:22:38 deployment. the discovery of his relationship and the continuing investigations of the inquiry.

03:22:48 inquiry. So whilst she wishes to help the inquiry to the extent that she's able to do so, she must protect her own privacy and that of her family as well. Overall, she continues to hope for three outcomes from this inquiry as it enters its next phase.

03:23:06 its next phase. First, she seeks openness, transparency, and answers to many of the questions that the inquiry sorry. First, she seeks some recognition. Recognition of the existence of undercover officers,

03:23:20 existence of undercover officers, spouses, their roles, and the impact and damage on them and their children. Second, she seeks openness, transparency, and answers to many of the questions that the inquiry is posing. She hopes that future witnesses will act with the requisite duty of cander that

03:23:33 with the requisite duty of cander that she, as I've indicated, has felt to be lacking in the evidence of many of those officers and their managers in TR 2. Applying the module issues to her own

03:23:45 Applying the module issues to her own experiences, some of the key things that she wants to understand are how were the married individuals selected for their undercover work?

03:23:56 undercover work? How much of a role did the fact that they were married to particular women play in this? Was the SDS in reality recruiting a package of a husband with supportive and loyal wife?

03:24:11 supportive and loyal wife? And the emphasis put on family life that created a culture that encouraged the officers to have more children despite knowing that they were at the same time betraying their wives.

03:24:24 Next, when the SDS was recruiting undercover officers, was there any assessment of the suitability of the

03:24:35 assessment of the suitability of the family and the family unit for this sort of work, or the impact it would have on them, or the risks and pressures it would expose them to? What explanations, asurances, or undertakings were routinely given to families of undercover officers? And

03:24:53 families of undercover officers? And were they true? Were these women lied to by the senior SDS officers they met about the nature and role of their husband's work? Next, what support was offered to the undercover officers? Were there any procedures the women weren't told about as to how they could raise concerns

03:25:04 as to how they could raise concerns about the impact of the work on the

03:25:15 about the impact of the work on the officers or their families? Or was this just not thought about? Why, when they did try to raise these concerns, were they not properly responded to? Next, training or support. Was this offered to other partners of undercover officers before or during their deployments?

03:25:32 deployments? If not, why did these officers wives like her not get any training or support?

03:25:38 support? And finally, who exactly within SDS knew about sexual relationships between the undercover officers and their targets? Were those relationships actively

03:25:49 Were those relationships actively encouraged or authorized? Why weren't the ex-wives told about the relationships at any stage before they were made public despite the MPS's awareness that this media bombshell was

03:26:02 awareness that this media bombshell was about to burst over their lives and that of their families?

03:26:10 Finally, for the future, S seeks from this inquiry the basis for asurances of five things. That there is no place in policing for

03:26:21 That there is no place in policing for intimate intimate relationships between an undercover officer and an unsuspecting target and that the law should reflect that.

03:26:32 should reflect that. Second, that no other undercover officer partners or their families will be exploited as S has been or go through what she has been through.

03:26:46 what she has been through. Third, that no other individuals will be subjected to sexual deceit in the name of policing. Fourth, that this inquiry identifies the lessons that can and must be learned

03:27:02 lessons that can and must be learned from the experiences of S and the very many others affected by these events. And fifth, that there is a cultural and systemic change in police attitudes towards women

03:27:13 change in police attitudes towards women to expune misogyny and sexual misconduct from policing. So that is the opening on behalf of S.

03:27:32 So that is the opening on behalf of S. Thank thank you very much for the clarity and force of your opening remarks. Uh they sink home. Thank you. Could you reassure s please that um

03:27:45 Could you reassure s please that um every step which the inquiry can take uh will be taken to ensure the privacy of herself and her family. I I'm grateful for that too. I I think she is following online but I will relay that myself personally as well. Thank you.

03:27:56 Thank you. We will now um adjourn until a quart 2.