20 March 2025

(2.00 pm)

Lady Hallett: Mr Sharma.

Mr Sharma: My Lady, the next witness is Dawn Matthias.

Lady Hallett: Thank you.

Ms Dawn Matthias

MS DAWN MATTHIAS (sworn).

Questions From Counsel to the Inquiry

Mr Sharma: Ms Matthias, you have helpfully provided the Inquiry with a witness statement, the reference for which is INQ000475069. Would you please confirm that’s true to the best of your knowledge and belief.

Ms Dawn Matthias: That’s correct.

Counsel Inquiry: Just by way of background to begin, you are a civil servant; is that right?

Ms Dawn Matthias: Yes.

Counsel Inquiry: You currently work as the commercial deputy director at the Crown Commercial Service?

Ms Dawn Matthias: Yes.

Counsel Inquiry: Between around 23 March of 2020 and July of 2020, you were seconded from the Department of Education to the Department of Health and Social Care; is that right?

Ms Dawn Matthias: That’s correct.

Counsel Inquiry: And your role was as a case worker working in PPE procurement?

Ms Dawn Matthias: That’s correct.

Counsel Inquiry: You are a member of the Chartered Institute of Purchase and Supply?

Ms Dawn Matthias: Yes.

Counsel Inquiry: You have worked in procurement for more than 25 years, both in the public and private sectors?

Ms Dawn Matthias: That’s correct.

Counsel Inquiry: Is it also right that you volunteered to assist in the pandemic response because of your experience in procurement?

Ms Dawn Matthias: I did, yes.

Counsel Inquiry: To begin, please, with your role as a caseworker, could you talk us through precisely what sort of responsibilities that entailed, involving your contact with suppliers and accumulation of documents for the next stage in the process that the Inquiry has already heard about.

Ms Dawn Matthias: Yes, of course.

So in the initial stages from being seconded on 23 March, for a period of seven to ten days I was a caseworker who was triaging offers of supply of PPE only, not ventilators or test kits, from what we would call “every supplier”. Around early April, I was asked to support a smaller team, and that team were the team which have been referred to as the HPL, to do the exact same role only for a different subset of suppliers.

So, from that date onwards my role as a caseworker would be to receive, on a daily basis, referrals that would be emailed to me at various points during the day, and those would be referrals of offers of PPE that were being offered from a number of different sources, some UK based, some globally based.

Counsel Inquiry: Thank you. So we’re in the Opportunities team, we are in the HPL; is that right?

Ms Dawn Matthias: That’s correct.

Counsel Inquiry: And there’s a particular category of referral which I’d like to ask you about, please, and they’re labelled VVIP referrals. Could you help us, please, with VVIP. What is that a reference to?

Ms Dawn Matthias: Okay, probably prudent to advise that, from my perspective the terms “HPL”, “VIP”, “VVIP”, were all used very interchangeably, and I think from a lot of caseworkers’ perspective in the HPL team we didn’t personally have any distinction, ie, there was no difference in how either a VIP, an HPL or a VVIP supplier would be processed. So I think, to answer your question, apologies, the term “VVIP” would have been a designation that caseworkers would have given to a very high-profile or senior referrer.

Counsel Inquiry: They’ve also been referred to in your evidence as category 5 referrals. Are they one and the same, VVIP and category 5?

Ms Dawn Matthias: Yes.

Counsel Inquiry: Could we have up, please, on the screen INQ000565104.

This is an email from you on 28 April. You refer to them here as:

“They are ‘Very Very Important People’ Basically suppliers who have made contact with us directly via [an] MP, Lord, Lady, PM private office, etc. [And] Cabinet Office are keen that they [have] a speedy response …”

Does that effectively summarise the position?

Ms Dawn Matthias: Yes, I would say so. I think this particular correspondence is me giving a – I guess describing, sorry, the expectation of the referrers to a relatively new recruit who had been seconded into the team.

Counsel Inquiry: Could I ask you, please, turning to your experience, your day-to-day experience with referrers and suppliers, in your witness statement page 4, paragraph 13, you describe them as “being very robust and assertive” with you, but you had experience in procurement. How was that for you, on a day-to-day basis, dealing with those referrers and those suppliers being in contact with you?

Ms Dawn Matthias: Okay, so typically the majority of the contact I would have would be with the supplier not the referrer, with the exception of one case. And I think, yes, it’s true to say that, you know, I’ve had experience of quite robust, assertive suppliers in the past. I think the big difference in this instance, in my experience, in supporting the efforts to secure PPE, would be the extreme persistence and the volume of that extreme persistence, which is relevant and kind of correlates with the number of cases that I’d be dealing with at any one time.

So it could – it wouldn’t be uncommon for me to have, you know, five or six hours’ worth of phone calls in any one day with up to 10 to 20 suppliers, and for those suppliers to be bearing their frustrations on me.

Counsel Inquiry: You, in common with a number of witnesses who have given evidence to this Inquiry, describe in your witness statement working 12-15 hours a day, seven days a week.

Ms Dawn Matthias: That’s correct.

Counsel Inquiry: Could we have up, please, on screen INQ000565319. Thank you.

This is an email you sent on 31 March of 2020.

Ms Dawn Matthias: Yeah.

Counsel Inquiry: Just if I could – please, if you could provide some context to this email, you refer here to being “promoted … to the VIP Supplier Team” –

Ms Dawn Matthias: Yeah.

Counsel Inquiry: “… allocated to dealing with the suppliers who feel it is important for them to contact Boris, Matt Hancock, Gove, Gareth & other Minister[s] … directly.”

And this part, if you would focus on, please:

“So now basically jumping through hoops to get quick responses to them before they complain that we are not taking it seriously.”

Just breaking that down, please, “jumping through hoops”, what did you mean by that?

Ms Dawn Matthias: So, again, I think I referenced this in paragraph 41 of my witness statement, so again, just against the backdrop of the extreme pressures that we were working under as well, at the time, not terminology that I would normally use. This is an exchange between myself and who – a person who was at the time a member in my team in the Department for Education.

Counsel Inquiry: Yes.

Ms Dawn Matthias: So I’m not directly linked to the efforts to procure. And it did feel, you know, often at times that we were jumping through hoops in the context of, I guess, the sheer workload and the diverse nature of what we were doing and who we were dealing with. And, you know, again, in the context of – I think it references further up “looney bin”, yeah, it does, and that was in the context of what we saw and witnessed.

So typically my role on a day-to-day basis, you know, involves working with a smaller number of suppliers on maybe one or two projects, and this situation, in comparison, was working with hundreds of suppliers who were offering to supply to the government anything from nutritional advice to knitted goods to fabric to really credible offers of PPE.

And in that context, it was a really bizarre situation, and I think also in the context of that being a continuation, it’s the 12-16 hours a day, seven days a week that, you know, we’re dealing with all of that –

Counsel Inquiry: Forgive me if I interrupt. That expression, “jumping through hoops”, suggests that some of the tasks that were being performed were pointless tasks. Have I got the wrong end of that?

Ms Dawn Matthias: They weren’t, in terms of the activities that we carried out as caseworkers. Those specific tasks weren’t pointless. Some of the offers which we did triage were pointless, ie, nutritional advice or a simple roll of fabric.

Counsel Inquiry: And those sorts of offers, were they coming in through the VIP Lane, as well?

Ms Dawn Matthias: My understanding is they were coming in through all channels, VIP and non-VIP.

Counsel Inquiry: Thank you. Could we have up on screen, please, INQ00565309. And the final paragraph, please. This is an email from you on 20 April. Again, I’d be grateful if you could provide some context to this, because it’s important that the Inquiry understands precisely what you mean here. You describe that the – you have been assigned VIP Suppliers team:

“… the ones who believe they are too important to complete a survey, as they have a link to a minister, or know Matt Hancock/Michael Gove, Jeremy Hunt, etc, and as such Cabinet Office ask us to contact them within 24 hours …”

A piece of evidence the Inquiry has heard before.

What was this like? It sounds here as though you’re exasperated with what you’re being asked to do. Could you help us, please, with that?

Ms Dawn Matthias: Of course. I wouldn’t say I was exasperated. We were very tired and sometimes frustrated, but equally, we were quite proud of what we were doing in terms of our efforts to secure PPE. This is an email that I sent to a colleague, again in DfE, who wasn’t involved with the PPE procurement, who had enquired with regards to how a supplier may be able to, you know, offer PPE.

So that’s the context of that.

In terms of ones believing to be too important to complete the survey, I think it is fair to say that the nature of the suppliers that were being triaged through the HPL team were senior contacts within the supply chain who wouldn’t be, I guess either adverse to, or used to being advised to complete a form. You know, it wouldn’t be – it would be inconceivable, I think, for them to be asked to do that so that is in respect to that context.

The contact within 24 hours, it was an aspiration of the HPL team to try to endeavour to make contact within 24 hours.

Counsel Inquiry: From your perspective, how frequently was that aspiration met?

Ms Dawn Matthias: Unfortunately I don’t have any statistics that would kind of give an accurate view on that, but I know from my perspective I didn’t always meet that target because of the volume, and sometimes if I did meet that target, it would be via way of what I would term a holding email back to the supplier to say, “We have your offer, please be assured we will, you know, be considering it in due course.”

So sometimes within a day, I could. It just depended on the caseload and the volume.

Counsel Inquiry: Thank you. Just to give an idea as to the volume of cases that you were handling, could we have up on screen, please, INQ000575149, and page 1.

Again, an email from you, 30 April 2020. And you provide an example, a snapshot, if you will, of your workload:

“… juggling 37 VIP cases (and more coming in) 6 non-VIP cases, 2 new NHS starters [your words] totally swamped, and despite doing 12-15-hour days [you] can’t keep up with the volume of emails …”

Does that fairly reflect not only a snapshot in your day but your experience in the VIP team as a whole?

Ms Dawn Matthias: It does, yes.

Counsel Inquiry: You refer in your witness statement and in an exhibit which you produced to connections with political parties. I wonder if we could bring this up.

It’s INQ000565246. Thank you.

12 May 2020, so a little further into the chronology. Emailing somebody again at the Department for Education.

Ms Dawn Matthias: Mm-hm.

Counsel Inquiry: And you say this:

“I would love for an FOI to be put in after all this to see the % of orders for PPE raised within the VVIP suppliers/those with party connections. I suspect it would be on the high side based on what I’ve seen going on.”

What had you seen going on, and what was it that led you to that conclusion?

Ms Dawn Matthias: Okay, so I think the email chain will provide some broader context and I think it’s paragraph 54 of my witness statement. This was in relation to my – I guess my curiosity in terms of how fruitful the work that the HPL team were doing, in terms of, I guess, in crude terms, return on effort. You know, the 12, 15 hours a day, seven days a week, lots of triaging, lots of processing, lots of difficult stakeholder conversations. And because of the, I guess the hectic environment that we were working in, caseworkers didn’t always get to understand if a case that we had been dealing with earlier had actually converted into an order because we lose sight of it as it gets handed off through the various stages.

So it was curiosity in terms of the percentage of cases we’ve triaged, in terms of what that would mean, in terms of order conversion. The language, “based on what I’ve seen going on”, was simply in the context of simply seeing how many cases were coming through the HPL.

Counsel Inquiry: Forgive me, Ms Matthias, you seem, at least in this email, to have expressed a view that it would be based on the high side, based on what you’ve seen going on. How and why did you form that view?

Ms Dawn Matthias: Okay, so on the high side in the context of the – not all, but certainly a large proportion of the cases that were being sent from referrers and processed at least to the point of technical assurance stage, were of high volume, and therefore a high quantity, which would naturally lend itself to being a high-value contract, compared to, again in my experience, at the early stages of processing non-HPL cases, typically some of those offers of supply were much smaller in terms of quantity, therefore would be much smaller in terms of volume and value.

Counsel Inquiry: You don’t identify, in this email at least, a particular political party, but did you have one in mind or was this just a general observation across the board?

Ms Dawn Matthias: It was a general observation.

Counsel Inquiry: All right. Could we have a look, please, at some of the kinds of referrals which you and those working within your team were receiving, just to see the range of individuals and parties and locations it was coming from.

Could we have INQ000565128.

This is just one example, and there are a number I am going to put to you and ask you about. This is an example of a referral coming in from a Labour peer, and this says that:

“… a Labour peer on its board who is making waves at very senior levels … There are two offers … in Mendix … looks like nobody has picked [them] up. Could we take them into VIP as VVIP cases, please.”

This was a referral from Salamanca. Could you help us please with whether you were given any guidance or steer about how you and your team were not only to deal with offers from ministers but also from offers from opposition party ministers or opposition party politicians?

Ms Dawn Matthias: Apologies, was that question in the context of how we would respond or how we would process the opportunity?

Counsel Inquiry: Well, both, but if you would deal first with how you would respond?

Ms Dawn Matthias: Okay, so I think it’s fair to say that the team of HPL caseworkers were versed in dealing with or were capable of conducting an acceptable level of stakeholder management. So –

Counsel Inquiry: Unpack that for me. What does that mean?

Ms Dawn Matthias: So, typically, it would have been manned by resources who had had experience of dealing with ministers or senior officials or senior people within the supply chain.

Counsel Inquiry: Could we have a look, please, at another example. INQ000565127. Again:

“Category 5. VIP. Note there’s a Labour peer involved who implied he’d go to select committee …”

The Labour peer, I think down at the bottom, is Lord Triesman:

“… if we didn’t quickly progress the company he’s on the board of.

“I should flag that while it’s [category] 5 VIP, I don’t think it has legs. We should still properly kick the tyres, though.”

This is an email from Mr Cairnduff that the Inquiry’s heard about. Is this the kind of email or offer that would be processed by somebody who was more senior in the team? How would it be done?

Ms Dawn Matthias: I think it would have been done by Max, from memory, and from my understanding, would provide a lady called Wendy Burdon in the team –

Counsel Inquiry: Yes.

Ms Dawn Matthias: – the list of referrers or offers, and then Wendy would disseminate them within the wider caseworker team. In that situation, I would receive what Wendy was sending to me, for example, and then I would make a judgement on which members of my team I felt were able to adequately deal with that particular offer.

Counsel Inquiry: I see. So you had in your mind, and as these cases are being allocated, that there would be people within your team that you considered would be capable and equipped to deal with ministers or people of that level of seniority?

Ms Dawn Matthias: I wouldn’t necessarily say I would allocate based on who I felt was able to deal with a minister or, you know, someone of seniority because, with the exception of one particular case, the contact between the referrer, which would be that senior minister or official, would cease at the point where we would be handed over or we would then make contact with the supplier directly.

I think what I would be cognisant of is when the senior stakeholders, ministers, were seeking updates, would the caseworker who was allocated that offer be capable of providing that communication with regards to progress in a timely manner, in a factual manner, and using the language that would be appropriate?

Counsel Inquiry: Thank you.

If we could turn, please, to INQ000565130.

Again:

“Category 5, VIP.”

The Inquiry has heard a little bit of evidence about this before in relation to referrals that were made in – by Rachel Reeves MP. It says:

“No ideas if this has priority – but it’s one of the 40 companies that [have been] raised.

“We don’t have details of their offer …”

And so on.

So, again, similar sort of processing.

Did it matter – the Inquiry has heard about processing of referrals from the Conservative Party, but I ask this neutrally: did it matter that a referral came in from somebody in the Labour Party?

Ms Dawn Matthias: As far as I’m aware, and I didn’t have that kind of level of exposure, given the role that I was doing at the time, the priority was based on the product in need, and that was the primary, you know, consideration.

I think, to your point, that would have been a secondary factor and I don’t – really don’t think – and certainly I didn’t see evidence of it having any impact, either negative or positive.

Counsel Inquiry: Could we have a look, please, at a slightly different category of referrer.

INQ000565172. Thank you.

If we zoom into the one at the bottom, this comes in from a journalist, from the BBC health editor.

Again, is there a different – is there a different way or means by which offers from people with access to journalists would be handled, or was that of no consequence to you and your team?

Ms Dawn Matthias: Not that I’m aware of. I would say it was of no consequence. It would be the priority of the actual PPE –

Counsel Inquiry: Did you or anyone in your team receiver training about how conversations with people such as this, journalists, opposition party MPs, ought to be conducted before you engaged with them? Or did you think that was unnecessary?

Ms Dawn Matthias: I don’t recall any formal training in that regard, and I think I would deem it to be – not unnecessary, but not required, given the experience of the caseworkers. So, you know, it’s just a given that we – we just don’t talk to journalists and divulge. And, you know, we all, kind of, are versed in how we handle information and how we communicate.

Counsel Inquiry: Would there not have been any particular risks in engaging in communications, even with somebody who is a journalist, to the way in which the PPE team was operating? If you think not a factor, then do say so.

Ms Dawn Matthias: I don’t believe so, no. I mean, it was commonly broadcast on a daily basis, certainly in the early stages of the pandemic, early stages of lockdown, that, you know, it was no secret that the country was in dire need of much needed PPE. It would have been outside the realms of the caseworker team to, I guess, even make a decision, let alone consider whether a communication with broadcasting authorities would be appropriate or not. And I’m conscious that the daily briefings were being provided from Number 10 as that kind of way of communication. So I don’t think it’s relevant, sorry.

Counsel Inquiry: All right. Another category, if we may, please.

INQ000565162.

Again, if we could zoom into the email, the second email down:

“As John mentioned, the Duchess of York has been in contact with Lord Deighton to try and help source PPE.”

Was there any training or guidance about dealing with people who were senior or high up or connected, for example, with the Royal Family?

Ms Dawn Matthias: Not specifically, no.

Counsel Inquiry: Was there any person in the team who would be allocated to handle such referrals from people in positions of power or with particularly high profiles?

Ms Dawn Matthias: From memory and from my understanding, royalty was sensitively handled by very senior people. So … but it was never – it was never a – it was never an issue. I don’t recall it ever being an issue. And I don’t recall it ever being widely discussed or ever receiving any direction that if I, for example, was ever directly approached by the Duchess of York, for example, I was forbidden, you know, to deal with that or not.

So I guess it was a case of when the referrals came in, they would come in to Max’s team, and then Max would make a judgement call on whether he felt he should retain that, because of whatever reason he felt, or whether he wanted to allocate it to an experienced caseworker who, I guess, he would have trusted were capable of handling such high-profile opportunities.

Counsel Inquiry: Another category, if we may, please.

INQ000565284. Three paragraphs down.

A reference to having links to people in China, to rulers, to senior bank officials and diplomats who might be “able to secure us [with] production capacity”.

So, again, another potential link, high profile, this time internationally. No training or particular caseworker allocated to deal with those connections?

Ms Dawn Matthias: No.

Counsel Inquiry: INQ000565432, please. Thank you. Just over the page.

Again, an email from you. An offer from an overseas royal family. Was there any particular means by which those people in your position and in your team were guided or instructed to deal with these very high-profile senior referrers in positions of power?

Ms Dawn Matthias: Again, there was no specific training or guidance provided. The allocation – sorry to repeat, but the allocation of these such cases would have been allocated to – you know, such as Max would retain it or Chris Hall or Darren Blackburn or myself, or Dennis or Richard. So I think it would be fair to say that between those individuals that I’ve just mentioned within the HPL lane, team, it wasn’t – it wasn’t written. It was just an understanding, I guess, of the capability, the commercial acumen, and trust, that we would deal with it in a – I guess in a timely manner, in an efficient manner. But there was no specific training. It was just an allocation based on capability and competency of the caseworkers available.

Counsel Inquiry: And based on what you’re saying, you’re indicating, if I may put it in these terms, that you had confidence in the ability of the team to allocate and deal win appropriately these sorts of senior referrals?

Ms Dawn Matthias: Yes.

Counsel Inquiry: Could we have up on screen, please, finally INQ000565322.

And again, this is an email from you, 31 March:

“Oh my word! I have just had an email via Lord Agnew via Michael Gove via some Royal in Dubai with links to what appears to be the most senior and wealthy people possibly in the world, offering to help. I didn’t take in the detail of the email, I was overwhelmed with the OBEs, the Sheiks and various different titles.”

And with some self-deprecation:

“… Cabinet Office think it is a good idea to give this to a Geordie to manage!”

Ms Dawn Matthias: Yeah.

Counsel Inquiry: Reflecting back on your experience of the High Priority Lane, and in particular of these sorts of referrals from people in positions of power, not only domestically but also overseas, do you think there was a case for some sort of guidance or some sort of specific process by which these kinds of referrals could have been triaged by somebody of greater seniority?

Ms Dawn Matthias: I think, yes, and no. I think, reflecting on where we were in March and early April 2020, we were endeavouring to secure PPE, and that was our primary aim.

The high priority – if I can just use the crude term “the high priority referrers and offers” –

Counsel Inquiry: Of course.

Ms Dawn Matthias: – were in my opinion triaged by the most appropriate, most experienced caseworkers available, or at our disposal.

Counsel Inquiry: And if I may ask, who were they?

Ms Dawn Matthias: So obviously you are aware of Max and his role.

Counsel Inquiry: Yes.

Ms Dawn Matthias: And the people which reported to Max. Max was more than able to make a very well-informed decision on which of these cases were allocated to the various caseworkers at his disposal.

I think, looking forward, and looking at how we could possibly approach it in five years’ time, ten years’ time, and this is just my opinion, my suggestion, based on this experience, would be for a more proactive response, which is difficult when, you know, it’s – an epidemic just lands, I get you can’t be that proactive but when I say that, I mean that from the perspective of applying what I would call a standard or a generic procurement approach to procuring anything.

We didn’t have that luxury at the time. But specifically, from the latter, in terms of the proactive approach, it could be that we give consideration to carving out a bespoke team to process, triage, deal with – whichever terminology – offers that weren’t being or couldn’t be dealt with in a proactive manner. And possibly for those individuals in that carved-out resource to be not commercial.

Counsel Inquiry: It’s a theme of the evidence from those who have come to the Inquiry and told my Lady about their experience in the High Priority Lane that it is inevitable, within a Parliamentary democracy, that people will get in contact with their MPs, get in contact with ministers, also that it’s inevitable that help will be offered from those who are overseas and who may have connections to people that could help us with acquiring PPE. Is that that team, that carved-out team, is that where you’re suggesting that those kinds of offers should be triaged? Or is it something different that you’re suggesting?

Ms Dawn Matthias: No, that’s what I was suggesting. And the difference between what was – crude, sorry – carved out in 2020, in terms of the caseworker teams, the Technical Assurance teams, the Closing teams, each one of those functions performed activities. We could give consideration to a carved-out team to handle those reactive call to arms, if that makes sense, but actually not do any of the activities. So ie, not initiate a technical assurance process, not to initiate further financial due diligence, not to initiate the awarding of a contract.

And my opinion, had that been in place, the caseworkers and the Technical Assurance team and the Finance team would have possibly been able to work more efficiently.

Mr Sharma: Thank you, Ms Matthias. I don’t have any further questions.

Lady Hallett: Thank you.

I think Ms Morris has questions now.

Ms Morris.

Questions From Ms Morris KC

Ms Morris: I do. Thank you, my Lady.

Good afternoon, Ms Matthias. I ask questions on behalf of the Covid Bereaved Families for Justice UK. You mentioned a moment ago the technical assurance process, and I’ve a few questions for you about that process, please.

Ms Dawn Matthias: Okay.

Ms Morris KC: And just so you understand, I am seeking to explore whether being referred through the HPL conferred a benefit to those in the HPL, in terms of its prioritisation within the technical assurance process. Okay? That’s my theme.

Mr James, Richard James, described in his written evidence that the HPL had a dedicated contact in the Technical Assurance team with whom the HPL team had regular liaison about the progression of offers. Is that something you’re familiar with?

Ms Dawn Matthias: I’m aware that there was a contact. I would question whether that contact was dedicated to HPL.

Ms Morris KC: Okay.

Ms Dawn Matthias: And I would also add that every caseworker, regarding of lane they were working in (sic), also had that access to the Technical Assurance team.

Ms Morris KC: Okay. He goes on to say that there was a process by which the Technical Assurance team would communicate feedback on the progress of offers and, if relevant, reasons for rejection. He says, as a result of this feedback, the HPL caseworker could resubmit the offer to the Technical Assurance team.

So do you agree with his description of the relationship between the HPL and the Technical Assurance team? He says “dedicated contact”.

Ms Dawn Matthias: Okay. Thank you. So I’ve addressed the dedicated contact because I don’t necessarily agree with that. However, I do agree with the ability for caseworkers to communicate to and from, between themselves and Technical Assurance, if – in the event that a product had failed the technical due diligence and needed to be resubmitted.

I would add to that, that in my experience and based on my experience, that was no different to general suppliers versus HPL.

Ms Morris KC: I’ll come to that, if I may. I’m going to ask you now to look at an email, please, sent on 23 April 2020 to the Technical Assurance team, and that’s INQ000565074, please.

That’s just at the top there. Thank you very much indeed. You say:

“Hi

“I spoke to Adrian last week and he was making some noise in relation to Lord Feldman as a result of the length of time it was taking to get his offering through TA [Technical Assurance] hence the chasers to MoD and giving [X] the heads up. I have today spoken to [X] in the TA team and he agreed to process their offering ASAP.”

So my question is, is it an example of escalating or expediting the technical assurance process of a VIP Lane offer, in this case one connected with Lord Feldman?

Ms Dawn Matthias: I don’t disagree with any of the text there I think the context is important. So – if I address it in this way and then you can tell me if it is answering your question.

So the caseworkers, whether HPL or not HPL, were aware that there was an ability to conduct what we referred to as a rapid response process. And the rapid response process was established by a means of being able to prioritise a particular item of PPE that was in the most need. So, for example, at any one point in time, if we were really, really desperate to secure gowns, for example, we, both HPL teams and non-HPL teams, would look within our cases to try and establish if we had an offer for that priority product and we would bring together caseworkers, Technical Assurance, Finance and Closing. So it could have been – I’m not suggesting it was, because I don’t know the context of this email, but it could have been I was applying some pressure on the Technical Assurance team to process a particular offer because it was for a dire piece of PPE. If that makes sense.

Ms Morris KC: All right. Mr James goes on to say in his statement that, he says:

[As read] “I don’t believe that the general Opportunities teams had a dedicated contact in Technical Assurance like we did on the HPL. Moreover, I considered that having this contact provided two potential advantages for the offers that we were processing on the HPL. First, we were able to communicate our priorities to that team to request that the highest priority offers in the HPL be processed more swiftly than other HPL offers of lower priority. Secondly, if we wished to obtain clarity on the reasons for a rejection, we could request the contact details of the relevant caseworker from the team and therefore communicate with them more directly and effectively than we could through Mendix.”

So I hear what you say about whether there was a dedicated contact in the TA, but would you agree with Mr James that there was two potential advantages to the HPL versus non-HPL offers?

Ms Dawn Matthias: I wouldn’t, no.

Ms Morris KC: Professor Sanchez-Graells, who has given evidence to the Inquiry, said in his evidence that it’s not accurate to say that all offers were treated the same from a technical assurance perspective because Technical Assurance was taking time, and having a dedicated person for technical assurance of VIP offers, would have accelerated things.

Do you accept his view regarding the benefit of faster consideration by the Technical Assurance team?

Ms Dawn Matthias: No, not based on my experience.

Ms Morris KC: According to Mr James, again from his written evidence, the HPL would chase up technical approval, including if the TA team didn’t respond within 48 hours and chase more frequently for updates than the general Opportunities team – and that’s paragraph 126 of his statement – and would contact the Closing team for updates on the referrer or offerer’s behalf if requested.

Do you think these additional steps conferred further benefits to HPL offers?

Ms Dawn Matthias: I don’t recognise those steps from the work that I conducted.

Ms Morris: Thank you.

Thank you, those are my questions, my Lady.

Lady Hallett: Thank you very much, Ms Morris.

That completes the questions we have for you, Ms Matthias. I’m really grateful to you. It must have been so tough in what I think we can understand you called the “looney bin”. They were extraordinarily long hours under pressure, so thank you for all you did at that time. It must have been impossible to have any kind of family life. And thank you for helping the Inquiry.

The Witness: Thank you.

Lady Hallett: Very well, I think that completes the evidence for this week, Mr Sharma?

Mr Sharma: Yes, it does, my Lady.

Lady Hallett: In which case we shall resume for the final week on Monday at 10.30. Thank you all very much indeed.

(2.47 pm)

(The hearing adjourned until 10.30 am on Monday, 24 March 2025)