Archived Transcript for 11 December 2001: Pages 1 to 51

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1 Tuesday, 11th December 2001

2 (10.00 am)

3 MR GARNHAM: Good morning. Sir as you know it had been our

4 intention this morning to call Mr Kousoulou and

5 Ms Wilson to give evidence. I regret to say that it is

6 not going to be possible for us to call Ms Wilson today.

7 On the evening of Thursday 6th December, last Thursday,

8 we received an additional witness statement from

9 Ms Wilson. It was not a statement we had requested, it

10 was volunteered to us by Haringey. It was received by

11 us and processed downstairs in the usual way.

12 You will understand I know that documents received

13 by the Inquiry have to be carefully logged and processed

14 so that we can manage the Inquiry process sensibly. The

15 system we have established downstairs is somewhat

16 time-consuming and labour intensive but it is thorough.

17 In the ordinary course new material like this is dealt

18 with in less than 24 hours. Friday and Monday however

19 have seen our document team at full stretch dealing with

20 the 630 new documents we have received from Haringey.

21 As a result Ms Wilson's statement was not dealt with

22 until the end of Monday afternoon and it was not given

23 to counsel who was to call Ms Wilson until 7.15

24 yesterday evening.

25 Ms Wilson was already an important witness for this

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1 Inquiry. Her new statement runs to some 30 pages of

2 closely typed text. It contains a point by point

3 response to the potential criticisms made of her and it

4 will plainly require careful consideration.

5 Accordingly, we found ourselves in the position last

6 evening of having an important and lengthy statement in

7 our hands which the interested parties had not seen and

8 which we had not by then had the chance to consider. It

9 is the sort of statement, sir, I have no doubt that

10 would prompt a number of the interested parties to

11 invite us to ask questions to the witness. In those

12 circumstances I made the decision that we should not

13 call Ms Wilson today.

14 I made that decision for three reasons. First

15 because it was impossible in the time available for us

16 as counsel to get properly to grips with the material

17 that was relevant to almost the whole of the evidence of

18 Ms Wilson we wanted to adduce. Second, because it would

19 have been unfair to Ms Wilson to deal with her important

20 evidence from a position of an incomplete understanding

21 of her position. Thirdly and perhaps most importantly,

22 it would have deprived the interested parties of any

23 chance to suggest lines of questioning with us and thus

24 put Ms Wilson in that regard in a different position

25 from all other witnesses we called.

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1 Sir, there it is. It is likely to mean a shorter

2 day today and I know that will mean that my learned

3 friends will feel cheated of the usual day's

4 entertainment we seek to provide and it will also more

5 seriously have a knock-on effect for the rest of the

6 Inquiry.

7 I can say at this stage that we envisage leaving

8 Thursday as we had planned. We will then call Ms Wilson

9 on Friday and Ms Richardson on Tuesday of next week.

10 Sir, we will let you know, if this is convenient to you,

11 the details of the changes to the timetable that follow

12 from that in due course. One of the possibilities we

13 are considering sir is sitting Tuesday, Wednesday and

14 Thursday of next week instead of Monday, Tuesday and

15 Thursday, but we will revert to you with further details

16 later.

17 Finally, can I offer my apologies to Ms Wilson for

18 the wasted journey she has had this morning and to thank

19 her for her cooperation in agreeing to attend instead on

20 Friday.

21 THE CHAIRMAN: Thank you Mr Garnham. I feel I am getting

22 into a position where I say I am deeply concerned more

23 times than I would wish to say, but I am very concerned

24 about the effect that this is having upon the Inquiry

25 and not just about the fact that it is increasingly

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1 lengthy and costly to the Inquiry but to the

2 inconvenience caused to everyone involved with this

3 Inquiry, and I will say more about that in a moment.

4 What I do think is, I do not know where Ms Wilson is but

5 wherever Ms Wilson is I endorse absolutely the apology

6 that you rightly have received from Counsel to the

7 Inquiry. I do not imagine it is much fun coming to give

8 evidence at an Inquiry of this kind and I expect that

9 people gear themselves up for that and it must be a bit

10 disconcerting to say the least to find that you have to

11 come back on another day.

12 I am grateful for the efforts that you are making

13 Mr Garnham to try and rescue the timetable and I look

14 forward to hearing from you. Now, I think that I am

15 going to hear from Mr Warwick.

16 MISS LAWSON: Yes, he is here.

17 THE CHAIRMAN: Mr Warwick, would you like to sit down.

18 I think you ought to be comfortable while I say

19 something to you.

20 Good morning Mr Warwick. I think it would be

21 helpful if you could tell me how long you have worked in

22 Haringey and how long you have been the Chief Executive.

23 MR WARWICK: I have worked in the London Borough of Haringey

24 since August 1995. I have been the Chief Executive

25 since May 2000.

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1 THE CHAIRMAN: Thank you. I do not know whether you have

2 taken an interest in the work of the Inquiry but

3 I imagine that you will recall that on 22nd January this

4 year your Council passed a resolution which went along

5 these lines, that Haringey Council cooperates fully with

6 the Ministerial Inquiry and makes appropriate resources

7 available to achieve this. Do you recall that?

8 MR WARWICK: I was responsible for that report to the

9 Council and it is my recommendation.

10 THE CHAIRMAN: Thank you. Well, if you have been taking an

11 interest in these matters you will no doubt remember

12 that Victoria died in February 2000, so we are a few

13 months away from the second anniversary of her death.

14 The trial ended in January of this year and it seemed

15 I guess clear to me as a member of the public, as I was

16 at the time, and I suppose everybody else, that Haringey

17 had a major contribution to make in our understanding

18 about what happened to Victoria and why it happened.

19 This became even clearer when the Government

20 announced immediately after the trial that an Inquiry

21 was to be held and I imagine that that is exactly why

22 you took that report as you did to your Council within

23 ten days of the end of the trial and the announcement of

24 an Inquiry.

25 MR WARWICK: My Council has accepted its share of

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1 responsibility in respect of this matter and quite

2 publicly at the time of the murder trial we made that

3 statement in good faith and we have always seen it as

4 our responsibility both to put right some of the

5 witnesses that exist within our own organisation, and

6 I believe over the last year we have put in an enormous

7 amount of effort to provide a safer environment both for

8 the children in our care but also the staff for whom we

9 are responsible.

10 We have also seen the benefits of the Inquiry being

11 carried out by yourselves. Obviously it is

12 a considerable drain on our resources and we would like

13 to see the Inquiry completed as swiftly as possible so

14 that any recommendations that you come up with can be

15 incorporated in the good practice we hope we are putting

16 in place within our Council at the moment. It is very

17 much in our interests as well as yours that the Inquiry

18 is able to report as soon as possible.

19 THE CHAIRMAN: Well, I take the sincerity of that statement

20 but for reasons that I will set out in a minute I have

21 to say the practice does not actually match the good

22 intentions. I do not know whether you have been briefed

23 on the contact that this Inquiry has had with your

24 Authority since we were appointed but I have before me

25 a summary of all of these contacts and if you have been

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1 briefed you will have a similar list.

2 I am not going to take up the time of the Inquiry to

3 rehearse all of these contacts because as you have

4 appreciated we have already got an issue about time but

5 what I would like to do is highlight some of the key

6 dates for you, because it was on 27th April that

7 a letter was sent to you as the Chief Executive of

8 Haringey with a list of documents requested, to be

9 returned by 21st May, and also a list of witness

10 statements to be returned by 5th June.

11 Now, since that time -- and I can go through these

12 if you wish but I think that I would prefer not to

13 because I do not think it is going to be in anybody's

14 interests to do that -- since that time there has been

15 regular contact with your Authority with numerous

16 requests for extensions of time in order to produce

17 witness statements and documents. At various stages

18 along this route we have been assured that we have

19 received all the things that we needed to receive only

20 for something else to appear which took us by surprise.

21 Even in June of this year a letter was sent to your

22 Authority saying that unless we received some witness

23 statements outstanding by 22nd June, witness summonses

24 would be served. We had a great deal of difficulty

25 getting the Part 8 review. We requested it for July, we

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1 got it on 20th August. That of course raised a whole

2 lot of other issues that needed to be pursued and we

3 have been pursuing those matters, not least issues

4 related to disciplinary procedures and other reports

5 that have come from that.

6 It is a long, sad and sorry saga of missed dates and

7 missed timetables, so much so that I have to say

8 reflecting my frustration -- and I have to say

9 frustration which I think was entirely justified, even

10 in the cool light of hindsight is entirely justified --

11 I issued a witness summons against the Director of

12 Social Services. I did with some reluctance but by this

13 time we were at the end of November and there were some

14 key documents that we needed to have.

15 Now, I expected in my innocence four or five

16 documents to be received last Monday. Instead we

17 received 630 plus documents and as you have heard from

18 counsel this morning all of these documents needed to be

19 processed, they all have to be copied to the interested

20 parties here, they all have to be incorporated in the

21 bundle.

22 In order to try and achieve that we took on extra

23 staff, at additional cost, and the system that we have

24 in place here did its very best and staff worked very

25 long hours to actually get that, to maintain our

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1 timetable. Sadly, this week we received five additional

2 witness statements and these are not just short

3 documents. You have heard from counsel this morning

4 referring to one that it is some 30 pages long. If we

5 are going to do justice to those witnesses and also to

6 do the job that we are required to do we have to rely

7 upon an efficient response from the different

8 authorities.

9 All of that would have been I think liveable with

10 but what is not liveable with is when we get documents

11 that relate to witnesses we have already seen that are

12 important documents.

13 I would like to take the example of

14 Miss Arthurworrey. You will know that Miss Arthurworrey

15 is a very important witness to this Inquiry. Earlier

16 this week we received a competency assessment done on

17 her by your Authority and this was done at the very time

18 that Miss Arthurworrey was just about to become the

19 social worker for Victoria. Sadly Miss Arthurworrey has

20 already given her evidence to this Inquiry and that

21 evidence was given without our knowledge of the

22 existence of this document.

23 It could well be that there are competency

24 assessments on other staff that we have seen and that

25 even now we do not know about these documents.

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1 Earlier this week Counsel to the Inquiry informed me

2 that he may need to recall witnesses that we have

3 already seen. In order to do a thorough job I would be

4 of course willing to consider that but you will

5 appreciate that the recall of witnesses will not only

6 increase the length but the cost of the Inquiry and

7 I regard that as a very, very serious matter indeed.

8 I have tried, and I guess that there will be

9 different views about this around the room, but I have

10 tried to be reasonable and understanding about this and

11 I will concede there may be other people who might not

12 entirely share that assessment and I have no doubt that

13 Miss Lawson and her team have tried very hard to be as

14 helpful as possible.

15 What I need from you basically this morning are the

16 following. First of all, I need to know are there any

17 other documents that we need to have from your Authority

18 in order that we can complete our task. Because every

19 time we get a document from your Authority it refers to

20 other documents and sometimes several documents that are

21 not known to us. Secondly, are there competency

22 assessments on other staff, other than

23 Miss Arthurworrey, staff that we may have seen or are

24 likely to see? Thirdly, and this is perhaps the thing

25 that is uppermost in my mind at the present time and why

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1 I have invited you here today, I think that you need to

2 advise me as to whether or not the experience that we

3 have had with Haringey hitherto is part of a deliberate

4 plan, despite your fine words, to actually prevent this

5 Inquiry doing a thorough job or whether, to be brutal

6 about it, it is just down to incompetency.

7 MR WARWICK: Can I deal with those in order? As to any

8 other documents, I cannot give you any guarantee that

9 every single document has been found that could possibly

10 be found. I do not think anybody could. What I will

11 give you is an assurance that we have put enormous

12 efforts -- I am sure you are aware of the effort that

13 went in last weekend to try and find any further

14 documents that we could. An instruction was given by

15 Mr Bristow to all staff to root out any documents which

16 may be considered relevant even if they are at the most

17 extreme, extremes of touching on relevance, in order

18 that we could come to you with whatever documents there

19 are within our possession.

20 As to the particular issue around the competency

21 assessments, I am not briefed to that level of detail.

22 I would have hoped that particularly in regard to the

23 particular document which is causing the difficulty at

24 this moment, that that should have come in earlier, and

25 I think that is accepted by my Authority, but I am sure

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1 that I will take soundings with the staff and if there

2 are any further issues we will go back and look for

3 them. My expectation is that there are no other

4 documents missing of this nature but obviously I will

5 check and we will come back to you.

6 The more important issue is the last issue which

7 I raise, which is the questioning, and I will accept,

8 I can understand your need to question the approach that

9 my Authority is adopting to this matter. I believe that

10 you have been copied with the statement made by the

11 Leader of the Council to our Council meeting last

12 Monday. I personally drafted that statement on behalf

13 of the Leader and therefore that statement sets out the

14 expectations of both the political and the management of

15 my Council as to the approach to the Inquiry and our

16 position. Have you seen that statement?

17 THE CHAIRMAN: That is a testing question Mr Warwick. You

18 may then bounce back at me and say I am incompetent.

19 I am not aware of that statement. Maybe I should be but

20 perhaps you would be kind enough to tell me what the

21 statement says.

22 MR WARWICK: I was going to ask your indulgence and read

23 that statement.

24 THE CHAIRMAN: If it is 30 pages long ...

25 MR WARWICK: It is two sides.

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1 THE CHAIRMAN: That sounds fairly long. Can you summarise

2 it?

3 MR WARWICK: If I may read it because I believe that this

4 actually sets out very clearly what we expected, and

5 I have to say to you I am acutely embarrassed to be

6 called here in respect of what has happened and in terms

7 of, I will deal with that, the specific issue after

8 I have read the statement. This statement was made by

9 the Leader in response to an emergency question raised

10 by the Leader of the Opposition. His statement said:

11 "Haringey Council has always fully supported this

12 Inquiry. The Council has endeavoured to ensure that the

13 Inquiry discovers the full story of the events leading

14 to Victoria Climbie's murder. I can draw the

15 appropriate conclusions to enable all agencies to learn

16 the lessons for protection of children in the future.

17 "Haringey as a Council accepted its responsibilities

18 in this case after the conviction of Marie-Therese Kouao

19 and Carl Manning for the murder of Victoria Climbie

20 in January 2001, and in his opening statement Mr Garnham

21 QC applauded the Council's stand.

22 "The Inquiry's terms of reference are wide. The

23 conduct of the Inquiry is in two phases. Firstly, to

24 investigate the events leading up to the death of

25 Victoria Climbie and secondly to learn lessons for the

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1 future. The Inquiry sought statements from a wide range

2 of individuals including councillors, employees and

3 ex-employees and the Council facilitated the production

4 of these statements and relevant documentation. Further

5 contributions were provided by individuals to the

6 Inquiry and the Council has been commended for

7 responding in a timely manner to the numerous requests

8 for additional information.

9 "The Council accepts it may have misunderstood the

10 way in which the Inquiry wished to conduct its business

11 in respect of Phase II, the lessons learned, and this

12 misunderstanding has only just become apparent. The

13 relevant information regarding the Inquiry has been

14 submitted as soon as available starting mid- 2001.

15 Frequent additions have been made as requested

16 subsequently.

17 "The Council has had three officers working

18 full-time supporting this Inquiry plus all other

19 relevant officers that is necessary. Indeed over the

20 last weekend 11 staff were in on Saturday and 21 on

21 Sunday to meet the needs of the Inquiry.

22 "The Council has also been placed on special

23 measures by the Secretary of State for Health and has

24 been radically improving the Children's Services in

25 order to provide a safer environment both for children

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1 in its care and its staff who work to protect them. We

2 have made significant changes to the management of the

3 service which have been recognised and commented

4 favourably upon by the Social Services Inspectorate.

5 Inevitably these changes have not always been welcome by

6 all parties, some of whom are giving evidence to the

7 Inquiry. I have seen the new working arrangements in

8 the Children's Service for myself and have discussed

9 them with the staff who assure me that the situation has

10 improved.

11 "We know there is more to do but we are getting

12 there fast. It was necessary that the Council made

13 changes and dealt with the operational management issues

14 to implement them. The Council was conscious that it

15 did not wish to be seen as pre-empting the work of the

16 Inquiry and has therefore not routinely submitted such

17 papers to the Inquiry. The vast majority of the 263

18 documents -- I think you said 630 earlier on --

19 submitted to the Inquiry today relate to events in 2001,

20 many since the Inquiry started. We have not uncovered

21 any new relevant documents in relation to the period

22 leading up to Victoria Climbie's death or events which

23 led up to it. We have adopted an approach of if in

24 doubt, put it into the documents submitted to them

25 today, whilst making it clear to the Inquiry that we are

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1 sensitive to the allegation that we are now swamping the

2 Inquiry and that is not our intention. The Council

3 apologises to the Inquiry if it believes our actions

4 have hindered their task but as I have set out before,

5 that has never been our intention."

6 Anybody who saw the Leader of the Council reading

7 that statement, which he only received five minutes

8 before, could not doubt the sincerity of his belief

9 along with mine that that has always been the intention

10 of our Council.

11 We believe, we accept that the way in which this has

12 been conducted with those large amounts of documents

13 turning up has not been helpful and we are prepared to

14 accept our responsibilities in respect of that matter.

15 As to the latest event, the reality is that what

16 happened was that you requested the competency

17 assessment on the day before the summons was issued, the

18 major request which was demanding four other documents.

19 A considerable amount of work went into providing those

20 four documents plus a whole range of other material

21 which we did not believe was required previously.

22 As I say we accept our error. It is a mistake on

23 behalf of my Council that that which had been requested

24 on 29th November was not sought at that time. If that

25 particular document had been in the file where it should

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1 have been it would have been found as a matter of

2 course. The truth of the matter is that that document

3 was not in that file and it was only when my staff were

4 reminded last week that they still had not provided this

5 missing competency assessment that a further trawl was

6 taken throughout all of our personnel records including

7 ones which are not believed to be related to the

8 particular individuals with whom we have dealt. It was

9 at that stage that the missing document was found.

10 I have to say that that document is one which

11 I would think would be seen as favourable to us rather

12 than unfavourable. Therefore there is no agenda for us

13 to need to hide it, which was not our intention because

14 in actual fact it is a document that would prove

15 favourable to our position. So I can assure you that

16 this is a genuine error on our part and we apologise to

17 the Inquiry for that.

18 I have said earlier that I am acutely embarrassed to

19 be here. It is not something that I relish and I offer

20 my profound apologies on behalf of the Council and that

21 also comes from my political leaders.

22 THE CHAIRMAN: Thank you for that. I take the sincerity of

23 that and I do not want to be churlish but -- believe

24 that -- there is one part of the statement that I want

25 you to comment on and that is where you said, and you

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1 drafted it, that the Council has been commended for

2 responding in a timely manner to the numerous requests

3 for additional information. Can I assume that none of

4 that commendation is thought to have come from this

5 Inquiry?

6 MR WARWICK: Some of the letters which have come from those

7 servicing the Inquiry have said thank you very much for

8 some of the things we have responded to. Obviously

9 I heard your words earlier on which gave a slightly

10 different view and I am not prepared to argue with them

11 obviously.

12 THE CHAIRMAN: I would hope the staff would always show

13 common courtesies but I would not like you, you or your

14 Council, to be left with the impression that I think we

15 have received material in a timely manner, which is the

16 phrase used in the statement.

17 MR WARWICK: I understand that.

18 THE CHAIRMAN: We do not want to be swamped with paper

19 I assure you. We have got more paper than -- you can

20 look around if you have any doubts about that. What we

21 must have and what you will understand I am sure we must

22 have, we must have the documentation in order to do

23 a thorough job and everybody is working incredibly hard

24 to do that thorough job and the fact that you are here

25 today is not the result of a whim. I would not want you

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1 to entertain any ideas of that kind. It is the result

2 of a build-up of frustration over the months that I set

3 out earlier on.

4 Whilst I will accept as I have said the sincerity of

5 what you have said this morning, I hope that you will

6 equally accept from me that this has been -- and I put

7 it in the past in the hope that we have put this behind

8 us -- this has been an extremely frustrating experience

9 but it has also been an experience which as you have

10 heard this morning has slowed down the work of the

11 Inquiry and that is something that I regret very much

12 indeed.

13 MR WARWICK: I understand that fully and as I say my

14 expectation was that when that statement was made then

15 that should have drawn a line under the concerns that

16 this Inquiry has and I regret that that was not the

17 case.

18 THE CHAIRMAN: I am grateful to you for coming along this

19 morning and for being so helpful and sincere in what you

20 have said. We still have a long way to go. Sometimes

21 it seems as if the road gets a bit longer and a bit

22 steeper as we go along. I hope very much that we will

23 not meet on this subject again, but you should know my

24 position which is if it becomes necessary we will.

25 MR WARWICK: I understand.

20



1 THE CHAIRMAN: Thank you very much.

2 MR GARNHAM: Thank you Mr Warwick, thank you sir. May we

3 then begin with the detailed business of the day.

4 I will ask Mr Sheldon to call the next witness.

5 THE CHAIRMAN: Mr Sheldon, thank you.

6 MR SHELDON: Could I call Dinos Kousoulou please.

7 MR DINOS KOUSOULOU (sworn)

8 MR SHELDON: Good morning.

9 MR KOUSOULOU: Good morning.

10 MR SHELDON: You have a file of papers on the desk in front

11 of you.

12 MR KOUSOULOU: Yes.

13 MR SHELDON: Can I ask what you say in it?

14 MR KOUSOULOU: These are documents that have been submitted.

15 MR SHELDON: Can I ask you not to refer to it for the time

16 being. If you feel at any stage during your evidence

17 you would like to perhaps you could indicate that and

18 also indicate the document that you are looking at, but

19 we will deal with that as we go.

20 MR KOUSOULOU: I have made some personal notes on my copies.

21 MR SHELDON: The same applies to those as well.

22 Could you confirm your full name and professional

23 address.

24 MR KOUSOULOU: My name is Dinos Kousoulou. I actually

25 operate from home. My address is --

21



1 MR SHELDON: I do not want that, thank you. You have made

2 two statements for use by this Inquiry. The first is in

3 volume 2 of the witness bundle starting at page 202.501

4 and it would be helpful if a copy of that could be put

5 in front of you. You have also more recently made

6 a second statement. That as I understand it is now also

7 in volume 2 of the witness bundle at page 202.493, and

8 I hope a copy of that can be made available to you as

9 well.

10 Sir, perhaps briefly for your benefit and for that

11 of the other interested parties I should indicate that

12 Mr Kousoulou's second statement, together with the

13 documents which appended to it, forms part of update

14 number 19 which I believe was distributed by the

15 documents team yesterday to the interested parties.

16 There is one point arising from those documents which

17 relates to document E of those appendices.

18 Unfortunately the original document E we were given only

19 had the odd numbered pages without the even numbered one

20 between them. That position was rectified by Haringey

21 Council earlier this morning and I have been told by the

22 documents team that a full copy of that document will be

23 distributed as soon as possible.

24 Mr Kousoulou, could you have a look at the last

25 pages of both of those two statements please. Are they

22



1 your signatures?

2 MR KOUSOULOU: They are.

3 MR SHELDON: And apart from the amendment that you make in

4 your second statement relating to the timing of the

5 staffing crisis are you content that the facts and

6 matters in both those statements are true?

7 MR KOUSOULOU: To the best of my knowledge, yes.

8 MR SHELDON: You started work for Haringey Social Services

9 in 1971, is that right?

10 MR KOUSOULOU: 1967 actually.

11 MR SHELDON: I see. Perhaps that is another amendment.

12 MR KOUSOULOU: Sorry, the department did not exist before

13 1971. I started in Haringey Council in 1967.

14 MR SHELDON: I see and you started off in Social Services at

15 least as an administrative officer in the finance

16 service.

17 MR KOUSOULOU: That is correct.

18 MR SHELDON: You had numerous other roles in administration

19 and management within Social Services before becoming

20 the Deputy Director in June 1998, is that right?

21 MR KOUSOULOU: That is correct.

22 MR SHELDON: And as such you were, in the period with which

23 we are primarily concerned, Mary Richardson's deputy?

24 MR KOUSOULOU: I was, yes.

25 MR SHELDON: You stayed in that role until March 2001 when

23



1 you left Haringey, is that right?

2 MR KOUSOULOU: That is correct.

3 MR SHELDON: Where did you go?

4 MR KOUSOULOU: I became self-employed.

5 MR SHELDON: Why did you leave?

6 MR KOUSOULOU: The Council had restructured the Housing and

7 Social Services Departments, basically split it into two

8 separate departments, and there was not a need for

9 a Deputy Director.

10 MR SHELDON: Thank you. You spent a few months as the

11 Acting Director after Mary Richardson's departure, is

12 that right?

13 MR KOUSOULOU: Between March and September, yes.

14 MR SHELDON: September 2000 being when the new Director

15 Anne Bristow came into post, is that correct?

16 MR KOUSOULOU: Anne came into post at the beginning

17 of October, yes.

18 MR SHELDON: I see. Who did your job for the four or five

19 months that you were doing Mary Richardson's?

20 MR KOUSOULOU: I retained some of my previous functions and

21 others were then divided amongst the Management Team.

22 MR SHELDON: So you were doing one and a half jobs and

23 various other people were picking up the other half,

24 were they?

25 MR KOUSOULOU: Probably one and a quarter rather than one

24



1 and a half.

2 MR SHELDON: Was that an arrangement that you found

3 manageable?

4 MR KOUSOULOU: Obviously it placed some strain on me but yes

5 it was manageable.

6 MR SHELDON: You tell us in your statement that you were

7 responsible for running the department's strategic

8 services, and for those of us less familiar with what

9 that means you go on to explain that that included IT,

10 personnel, training and finance; is that right?

11 MR KOUSOULOU: Correct.

12 MR SHELDON: Those were your principal functions?

13 MR KOUSOULOU: There were a number of others but they were

14 the main functions.

15 MR SHELDON: In addition of course to deputising for the

16 Director whenever she was absent. You were responsible

17 for about 120 staff, is that right?

18 MR KOUSOULOU: That is about right.

19 MR SHELDON: Could you have a look at your job description

20 in volume 16 starting at page 62. Is that a document

21 with which you are familiar?

22 MR KOUSOULOU: That is correct.

23 MR SHELDON: I wonder if I can invite you to turn to page 63

24 because much of what is on the first page you deal with

25 in your statement. There are a number of these specific

25



1 areas of responsibility which I would like to confirm

2 with you. Firstly, paragraph 6:

3 "Be a member of the departmental Management Team

4 contributing to the leadership, direction and vision of

5 the department and to the development and implementation

6 of policies and strategies."

7 That you saw as part of your role, did you?

8 MR KOUSOULOU: That is correct, yes.

9 MR SHELDON: Next one down, second half of paragraph 7:

10 "To maintain an ongoing dialogue with elected

11 members including responding to specific issues raised."

12 Again yes, part of your job?

13 MR KOUSOULOU: Correct.

14 MR SHELDON: Paragraph 8:

15 "To take a lead in and/or contribute to the

16 development of policy and strategy across the

17 department."

18 Again something you were aware that was part of your

19 responsibilities?

20 MR KOUSOULOU: It was, yes.

21 MR SHELDON: And then the last one that I wish to refer you

22 to in particular, paragraph 14:

23 "To develop and implement a comprehensive

24 information strategy for the division and ensure that

25 the division's information technology needs are

26



1 reflected in the corporate strategy."

2 Again that is you, is it?

3 MR KOUSOULOU: It is.

4 MR SHELDON: Thank you. You deal in paragraph 6 of your

5 first statement with something that you title "April

6 2000 Restructuring". You refer to the effect of that

7 restructuring on your department. Do you have that in

8 front of you?

9 MR KOUSOULOU: I do, yes.

10 MR SHELDON: Just so we are clear at the outset, we have

11 heard evidence from other former and current employees

12 of Haringey that there was a restructuring which took

13 place over the greater part of 1999 and into 2000, one

14 of the consequences of which was a reduction in team

15 managers from 12 to 6. Is that the restructuring you

16 are talking about there?

17 MR KOUSOULOU: As you say the restructuring was ongoing.

18 The Director Mary Richardson took a view that we should

19 not rush into the restructuring so it was phased over

20 a long period of time. Up until April it was the senior

21 management structure that was put in place and then the

22 rest of the structure followed that. So by April the

23 senior management restructuring had been completed.

24 MR SHELDON: But there is no new restructuring in April 2000

25 about which --

27



1 MR KOUSOULOU: No, it was part of the same process.

2 MR SHELDON: Thank you. Can we start at the outset in that

3 case by getting the chronology in place. When was the

4 decision taken to start this process of restructuring?

5 MR KOUSOULOU: Again, this is off the top of my head,

6 I think it was May 1999 that the first formal reports

7 were put to members.

8 MR SHELDON: Can you help us with when the process started?

9 MR KOUSOULOU: In what respect?

10 MR SHELDON: When did you start -- presumably the way in

11 which things work in a local authority such as yours is

12 this: management devise a plan. That plan is put to

13 members for approval. That approval is obtained and

14 then that plan starts to be implemented. It is the date

15 when it starts to be implemented that I am after.

16 MR KOUSOULOU: I think the first implementation phase

17 started with Andrew Turnbull, who was the AD for

18 Children and Adults Provider Services, being seconded to

19 the SSI which was unpredictable. It certainly was not

20 part of the original scheme but with Andrew's departure

21 the Director made a decision to actually begin the

22 process probably earlier than was planned, so his

23 functions were then put into the new structure as it

24 would have been.

25 MR SHELDON: I am just trying to get some sort of idea of

28



1 timeframe and how long this process was going on for.

2 MR KOUSOULOU: From memory the original report was put to

3 members in May. Andrew Turnbull I think left the

4 Authority on secondment to the SSI in June and that is

5 when the first practical phase of the restructuring

6 commenced. It was then not concluded until probably

7 18 months later.

8 MR SHELDON: I see.

9 MR KOUSOULOU: Completing the whole restructuring process,

10 over a number of phases.

11 MR SHELDON: This is a restructuring which impacted on all

12 areas of Social Services?

13 MR KOUSOULOU: Yes, there were a number of changes

14 throughout the department.

15 MR SHELDON: Were you involved in the formulation of the

16 proposals to members relating to this restructuring?

17 MR KOUSOULOU: The broad proposals were put forward by the

18 Director, they were certainly discussed with the

19 Management Team and it was made clear that we could have

20 a contribution to the overall proposals but the

21 mainframe work of the proposals had been agreed with

22 members and so we were very much looking at the

23 implementation and looking at issues around other ways

24 of changing the plans on a minor basis. The whole

25 framework was set by the Director in consultation with

29



1 members.

2 MR SHELDON: So you were consulted but at the stage at which

3 you were consulted the basic outline of the proposals

4 were in place and not subject to change by you?

5 MR KOUSOULOU: Certainly the framework it was made clear had

6 been agreed and it was what the Director wanted to

7 implement.

8 MR SHELDON: Was is it a framework that, when you considered

9 it for the first time, that you supported?

10 MR KOUSOULOU: The framework I had no problem with at all.

11 MR SHELDON: Did you have any doubts in your role as Head of

12 Personnel as to the effect it might have on the

13 workforce?

14 MR KOUSOULOU: Certainly one of the things that the Director

15 asked is for a number of members of the Management Team

16 to actually recall the previous reorganisation, the

17 major reorganisation in the Council which was 1993, and

18 brought together the Housing and Social Services

19 Department. It is very much a question of lessons

20 learned and I was one of those that were asked to map

21 out lessons learned and things to avoid in moving this

22 restructuring forward.

23 MR SHELDON: In order to minimise the detrimental effect on

24 the workforce?

25 MR KOUSOULOU: That is correct.

30



1 MR SHELDON: And that was your particular area of

2 responsibility as Head of Personnel, was it?

3 MR KOUSOULOU: Yes.

4 MR SHELDON: What was the point of this restructuring? Was

5 it just to save money?

6 MR KOUSOULOU: No, I think that was an issue as

7 a consequence. Certainly the Director's view was that

8 there was not a sharp enough focus on the management of

9 the department, a number of functions were spread

10 between divisions, for example there was not a single

11 children's division within the department. The

12 commissioning function was in one division, the provider

13 function was in another division and that was of concern

14 to Mary Richardson and there were a number of other

15 provider commissioning splits that needed to be tidied

16 up, and the other emphasis was to make sure there was

17 a single focus around housing.

18 MR SHELDON: So a need for an improved, more streamlined

19 management focus was identified and if that happened to

20 save money then so be it?

21 MR KOUSOULOU: Yes.

22 MR SHELDON: But it was not that we have got to find £80,000

23 a year from somewhere, let us cut some staff?

24 MR KOUSOULOU: There were clear pressures on the department,

25 as there have been for a number of years, to reduce its

31



1 budget and that was an ongoing matter.

2 MR SHELDON: Was there also an element of the plan to the

3 effect that some managers in whom senior management had

4 lost confidence needed to be got rid of?

5 MR KOUSOULOU: I think you would need to address that to

6 Mary Richardson. That was not my understanding behind

7 the restructuring.

8 MR SHELDON: Perhaps you could have a look, please, at the

9 statement of Carol Wilson which is in volume 3 of the

10 green files, starting at page 83. If I could ask you to

11 turn over, please, Mr Kousoulou, to page 91,

12 paragraph 3.2.5, about halfway down that paragraph

13 Ms Wilson says that drivers for change -- and she is

14 referring to this process which we are discussing --

15 were the need to have a devolved management structure

16 and long-standing concerns regarding some front line

17 management practice and supervision including areas of

18 poor performance.

19 Is that something of which you were aware at the

20 time, that that was one of the key drivers for this

21 change?

22 MR KOUSOULOU: Certainly the Director wanted to deal with

23 matters of poor management and poor performance, that

24 was a general concern and something that she wanted

25 addressed, whether through the restructuring or through

32



1 other means.

2 MR SHELDON: So there is nothing there that you quibble or

3 take issue with?

4 MR KOUSOULOU: No.

5 MR SHELDON: Could you have a look at volume 45A,

6 page 150.680. This is part of the statement given by

7 Carol Wilson to Mr Monaghan in his inquiry after

8 Victoria's death and if you look at the third paragraph

9 down on that page you see the following:

10 "We had a layer of weak managers who were not making

11 headway in the new agenda. The redirecting model had

12 high principles but was underpinned by an assumption of

13 the Director of the Corporate Services that there was

14 money to be saved."

15 Again, do you regard that as an accurate reflection

16 of what the Council was about in its restructuring?

17 MR KOUSOULOU: It was not the main focus of the

18 restructuring but the department was under pressure to

19 save money and certainly one of those pressures which

20 I think I highlighted in one of my statements was to

21 reduce the management infrastructure.

22 MR SHELDON: Because it would appear that there are three

23 specific objectives indicated by these references.

24 There is the more devolved and more modern management

25 structure, there is the addressing of poor performing

33



1 managers and there is the saving of money. Now, you

2 accept, do you, that they were all factors feeding into

3 this decision to restructure but you would rank them in

4 that order?

5 MR KOUSOULOU: I think I would, yes.

6 MR SHELDON: If you keep that page open you will see that

7 Ms Wilson indicates there further down that the cost

8 savings were going to be £80,000 in the first year and

9 120 thereafter. Was that your understanding?

10 MR KOUSOULOU: Certainly for this round of cuts and the next

11 round of cuts each service was given a specific target.

12 That was partly introduced as a way of actually

13 distributing the cuts to protect the services that the

14 Council felt were most valuable and so Children's

15 Services were allocated a sum of money to save.

16 MR SHELDON: You indicated earlier that one of the specific

17 jobs you were given within the context of this

18 restructuring process was to consider the effect on

19 staff and to minimise the detrimental impact upon them.

20 How did you go about working out how to do that?

21 MR KOUSOULOU: First it was in relation to the timeliness of

22 the change and the Director had already made a decision

23 that these would be phased over a period of time.

24 Mary Richardson had already made it very clear that she

25 wanted to consult staff directly and held a number of

34



1 open meetings across the department both for managers

2 and front line staff, both to sell the model and to

3 receive concerns and issues that staff wanted to raise

4 with her directly, and these were phased over a period

5 of time.

6 This was not a single meeting, it was a number of

7 meetings on an ongoing basis. The issues as far as

8 I was concerned, the critical issue was to make sure

9 there was ownership and a clear understanding of what

10 was trying to be achieved through the change process.

11 MR SHELDON: Can you explain what you mean by ownership?

12 MR KOUSOULOU: That people understood what the Director

13 wanted to achieve and had an opportunity to raise

14 concerns so that ultimately the changes that were being

15 made had some approval or general approval within the

16 department.

17 MR SHELDON: That was your contribution to this area of the

18 restructuring. How did you go about ensure that that

19 ownership was achieved?

20 MR KOUSOULOU: Certainly within my own division I had

21 regular meetings with the managers and staff that were

22 directly affected.

23 MR SHELDON: What about the other divisions?

24 MR KOUSOULOU: With the other divisions all the Management

25 Team in fact accompanied Mary Richardson on these open

35



1 visits and there was an expectation that the other

2 assistant directors would also have local meetings.

3 MR SHELDON: So you would expect, would you, a member of

4 staff affected by these restructuring changes to say

5 something along the lines of, "We were kept fully

6 up-to-date about these changes. We were involved

7 adequately and properly within them. We were given

8 ownership for them and this was achieved via open

9 meetings with Mary Richardson and briefings by our

10 managers"?

11 MR KOUSOULOU: We also had an internal newsletter that

12 carried specific articles about the restructuring.

13 There was a special edition covering the restructuring

14 principles. Each member of staff was actually sent

15 a questionnaire to fill in and return through their

16 managers and these were audited to make sure that we got

17 all those back.

18 MR SHELDON: We will come on to what the staff did seem to

19 think about that in a moment. Before we deal with the

20 specifics can I ask you this question on a general

21 level. Did your experience of the restructuring process

22 lead you to the same view that was expressed by

23 David Duncan when he gave evidence to this Inquiry that

24 it was flawed from the outset?

25 MR KOUSOULOU: No, I do not think it was flawed from the

36



1 outset. I think there were a number of issues and

2 problems with it but it certainly was not flawed from

3 the outset.

4 MR SHELDON: At the end of this process or very close to it,

5 as you indicate at paragraph 9 of your statement, your

6 first statement, a new Chief Executive arrived and

7 wanted to restructure all over again with the effect

8 that your role was deleted.

9 MR KOUSOULOU: That is correct.

10 MR SHELDON: One might take the view, and if it is wrong you

11 will explain why it is wrong, that it cannot have been

12 a particularly sound restructuring that was embarked

13 upon in early 1999 if the new Chief Executive as soon as

14 he comes in post has to start all over again.

15 MR KOUSOULOU: The main change that the new Chief Executive

16 brought in was to separate functions out of the

17 department. I am not aware certainly at the time that

18 I had left the Council that there was any internal

19 changes to the management structure of the department,

20 so the changes the Chief Executive brought in was to

21 move housing benefits out of Housing and Social Services

22 and to move the housing service out of the Housing and

23 Social Services as a single entity.

24 MR SHELDON: So the restructuring the new Chief Executive

25 did did not undo the work that had been done in the

37



1 former one?

2 MR KOUSOULOU: Not as far as I am aware.

3 MR SHELDON: Is Haringey open to the charge that it just

4 restructures for the sake of it in order to avoid having

5 to do anything particularly difficult to improve

6 practice? It just restructures the department instead?

7 MR KOUSOULOU: Inevitably there were a number of minor

8 changes to the organisation. All organisations change

9 and evolve. As far as any major changes are concern, as

10 far as Housing and Social Services, prior to these

11 changes which were headed "Redirecting the work of the

12 department", the last major change was in 1993.

13 MR SHELDON: Could you have volume 28A page 181. This is

14 a letter if you turn back to 179 you will see to

15 Carol Wilson from Peter Lewington who describes himself

16 as Social Services Convenor at the bottom of 183. If

17 you look at 181, you will see a heading about two-thirds

18 of the way down the page called "Restructuring Fatigue".

19 This is written as a result of consultations he had with

20 members of staff following the announcement of the

21 restructuring proposals.

22 Perhaps you could just glance quickly through that

23 paragraph and I will ask you to comment on a number of

24 points. Although you have indicated that the last major

25 restructuring was in 1993 prior to the one with which we

38



1 are concerned, he seems to indicate that this was in

2 fact a fairly regular feature of life for people within

3 the teams that we are concerned with. He says:

4 "Many staff are just very tired of these exercises

5 which have been a regular feature of life in this

6 department for many years. Children and Families Team

7 reorganised their Duty systems the previous year.

8 People do become stale and exhausted by constant, often

9 ill thought out reorganisation. I have often thought

10 about this department that the management approach has

11 tended to be that when there is a problem, rather than

12 address it directly the response is to have another

13 restructuring."

14 What is your view of that?

15 MR KOUSOULOU: Within services -- and certainly the

16 pressures on Children and Families were huge and that is

17 probably the one area where there were significant

18 legislative changes brought in by the Government -- it

19 is inevitable that the organisation will need to change

20 in response to the new requirements and I would have

21 some sympathy with Peter Lewington to say that Children

22 and Families areas were reorganised but this was very

23 much in response to service evolvement, and whether it

24 was unrealistic and whether staff had restructuring

25 fatigue I cannot comment. It was certainly not brought

39



1 to my attention and I am not aware that Children's

2 Services were restructured on a regular basis. I am

3 aware of a number of changes being made from 1993 until

4 the departmental restructuring.

5 MR SHELDON: You were not aware that this was a feeling

6 within the staff that they were constantly being shunted

7 around as a result of ill thought out restructuring just

8 for the sake of it?

9 MR KOUSOULOU: Certainly staff had expressed views in open

10 meetings that, "Is this going to be any different from

11 other restructurings?" Staff certainly expressed views

12 on the back of the number of the budget reductions over

13 the years. Structures had to be changed because

14 management arrangements had to be changed and could not

15 see an end to those changes. Those views were certainly

16 being expressed.

17 MR SHELDON: This is a problem whichever way you look at it?

18 MR KOUSOULOU: Yes.

19 MR SHELDON: Either they are right and restructuring is just

20 undertaken for the sake of it, and I accept what you say

21 about that, that your view is no, but even if the answer

22 is no, it was not just being done for the sake of it,

23 the fact that staff think it is and are upset and

24 disillusioned as a result of it is a problem from

25 a personnel point of view in any event, is it not?

40



1 MR KOUSOULOU: Absolutely and certainly one of the things

2 that was made clear to the Director around lessons

3 learned was that the end product of the restructuring

4 had to be worth the disruption it inevitably causes and

5 nobody in any organisation likes change. It does bring

6 with it a number of factors that need to be addressed

7 through the process.

8 MR SHELDON: So this sort of discontent amongst the staff

9 group was something that was recognised at the beginning

10 and a conversation along the lines of, "You cannot make

11 an omelette without breaking eggs" was had, was it?

12 MR KOUSOULOU: Certainly as I say from my experience no

13 restructuring, even the restructuring fully owned by

14 staff, is fully accepted and something that is looked

15 forward to. There is always an element of fear and

16 concern about change.

17 MR SHELDON: But as a result of that discussion or those

18 discussions at the time one of your specific areas of

19 responsibility was identified as ensuring that that

20 impact was minimised as far as was possible.

21 MR KOUSOULOU: Yes.

22 MR SHELDON: Would you accept that from a personnel point of

23 view this restructuring process was handled badly?

24 MR KOUSOULOU: There were elements of it in hindsight that

25 could have been managed better.

41



1 MR SHELDON: Should it have taken place over the summer?

2 MR KOUSOULOU: The changes that took place over the summer,

3 certainly in the first year, affected the senior

4 Management Team who were fully aware of the consequences

5 and the drivers behind the change. As far as I know the

6 other changes that affected other staff, I mean, were

7 partly delayed because the trade union requested more

8 time for consultation which did then drag it over the

9 summer period.

10 MR SHELDON: But the initial plan was to interview team

11 managers, for example, for their jobs in the summer. In

12 the event it ended up being late summer, September, but

13 the original plan was it was going to be July.

14 MR KOUSOULOU: July from memory, that is correct.

15 MR SHELDON: Should that have been the plan?

16 MR KOUSOULOU: I cannot see the timing of it and the time of

17 year is a significant factor. It was planned to be

18 before the main summer holiday period so people were

19 available.

20 MR SHELDON: Volume 28A page 178.517 please. If you flip

21 back one page you will see where this comes from, it is

22 a memorandum written by all staff at the North Tottenham

23 District Office copied in to you as well as to

24 Mary Richardson and Carol Wilson.

25 If we go over to 178.517, the first main paragraph

42



1 says:

2 "Sadly the workers in this District Office have

3 experienced at least two instances where children have

4 died. The inquiries that have been held subsequent to

5 these deaths have pointed towards issues where

6 improvements could be made in both practice and

7 procedures. We recall very clearly one recommendation

8 that was made from one of these inquiries which stated

9 that any change in the structure of the department

10 should be well organised and should not occur during the

11 summer months."

12 Do you know what they are talking about?

13 MR KOUSOULOU: I am not aware of the specific issues that

14 they were talking about in relation to children's deaths

15 in previous reorganisations.

16 MR SHELDON: When you got that memo that was news to you,

17 was it, that you should not restructure in the summer?

18 MR KOUSOULOU: As far as I am concerned the restructuring

19 that was planned would have culminated in interviews

20 being held in July which was before the main summer

21 holiday period, and clearly the main summer holiday

22 period is an area that we would try to avoid, and that

23 they were planned to occur before the main summer

24 holiday period.

25 MR SHELDON: So what is the main summer holiday period?

43



1 MR KOUSOULOU: Before schools break up, end of July

2 through August to early September.

3 MR SHELDON: I see.

4 MR KOUSOULOU: And these interviews originally were planned

5 earlier on in July before what I would call the main

6 summer holiday.

7 MR SHELDON: They did not happen then though?

8 MR KOUSOULOU: No, because the trade union requested

9 a deferment for further consultation and we agreed to

10 that deferment.

11 MR SHELDON: You say that you were aware and senior

12 management was aware from an early stage that this was

13 going to have at least some negative impact on staff.

14 You as head of personnel of a large organisation such as

15 Haringey are aware that the threat of job losses has

16 a serious impacted on a workforce. People become

17 distracted, they can become demotivated, they can leave

18 in anticipation. That is all right, is it not?

19 MR KOUSOULOU: That is not uncommon.

20 MR SHELDON: The key thing one might say in that sort of

21 situation is to ensure that workers are kept as fully

22 informed as possible of what may be happening to them.

23 You will agree with that?

24 MR KOUSOULOU: Absolutely.

25 MR SHELDON: Carol Wilson says in her statement, I will not

44



1 take you to it at the moment in case you need to have

2 your memory refreshed but she says that the briefing for

3 the changes was delegated to commissioning managers so

4 that the commissioning manager for example for the North

5 Tottenham office would be responsible for briefing down

6 the proposals, and similarly in Hornsey was that

7 understanding as well.

8 MR KOUSOULOU: The details were to be briefed down, briefing

9 packs were prepared for all managers and part of that

10 pack was a form to be given to staff to return that they

11 had been properly briefed and understood the

12 information, so it was done in a very well organised

13 manner.

14 MR SHELDON: Was it fed back to you during the course of

15 1999, the middle part of 1999 that this process was not

16 working very well?

17 MR KOUSOULOU: No, that was not the case. In fact the

18 feedback I had was the opposite and that we had.

19 MR SHELDON: Really?

20 MR KOUSOULOU: We had returns from the majority of staff

21 that they had been properly briefed.

22 MR SHELDON: Could you have volume 26B page 20.509. Just so

23 I explain at the outset, Mr Kousoulou, what I propose to

24 do here is to take you through a number of documents in

25 chronological order with a view to trying to understand

45



1 exactly what information was being given to what staff

2 at what times.

3 These are the North Tottenham District management

4 minutes of a meeting that was held on 10th March 1999.

5 If you look at page 509, we see the first reference to

6 this restructuring process that I have been able to find

7 under the heading "Restructuring Information". Do you

8 see that?

9 MR KOUSOULOU: Yes.

10 MR SHELDON: It says "Dave's memo re 18th March 1999." The

11 structure is there set out, six posts will go.

12 MR KOUSOULOU: Sorry I do not have that.

13 MR SHELDON: Do you have page 020.509?

14 MR KOUSOULOU: Yes.

15 MR SHELDON: About halfway down "Restructuring Information."

16 MR KOUSOULOU: Yes.

17 MR SHELDON: So at this stage in March 1999, which is

18 slightly earlier than the chronology that you indicated

19 at the outset, team managers were aware that six posts

20 were going to go and that there would be a new post

21 called Deputy Team Manager. Do you see that?

22 MR KOUSOULOU: Yes.

23 MR SHELDON: Could you go on in that volume please to

24 page 26. This is a meeting that you will see if you go

25 to page 25 of the same team on 16th June 1999, and

46



1 item 2 on the agenda on page 26 is "Restructuring." It

2 indicates there that interviews from team managers have

3 now been brought forward to July and August. They are

4 to be in post by September 1999. There will only be six

5 posts. There are fewer redeployment opportunities than

6 first thought. Some team managers may be asked to

7 become deputy managers. There may be vacancies in the

8 youth offending team. Deputy managers, this is still

9 undecided. Temporary senior practitioners are

10 potentially more vulnerable. It does not paint

11 a particularly clear picture as to exactly what is going

12 on, does it?

13 MR KOUSOULOU: Certainly the revised structure in Children's

14 was clear. There was going to be a reduction in team

15 managers and there was going to be an increased number

16 of senior practitioners with the team managers taking

17 lead role in managing the infrastructure of the service

18 and the team managers managing casework. That was the

19 driver behind these changes. That was absolutely clear

20 and the numbers were clear.

21 MR SHELDON: But these people are in the front line. They

22 are the ones whose jobs are in the balance.

23 MR KOUSOULOU: Yes.

24 MR SHELDON: In June 1999 it looks like the interviews are

25 going to be moved. These are interviews for which they

47



1 have to revise quite heavily we have been told and are

2 quite testing. They have been moved. There are fewer

3 redeployment opportunities than first thought. They may

4 be asked to become deputy managers. There may be

5 vacancies elsewhere. They have not decided what the

6 deputy managers are going to look like yet. It is not

7 particularly clear, is it? These interviews are

8 supposed to be in the next month.

9 MR KOUSOULOU: The interviews for the next month, as far as

10 I can recall, were for team managers and I think the

11 position around team managers was absolutely clearly.

12 MR SHELDON: You get that from these minutes, do you?

13 MR KOUSOULOU: These are minutes. I was not at the meeting.

14 MR SHELDON: I know.

15 MR KOUSOULOU: It is obviously a summary of the discussion

16 that took place. I was not there. I do not know how

17 accurate a summary this was. All I can say is that the

18 structure as far as Children's were concerned, the

19 revised management structure was clear and the numbers

20 were clear. The issue around redeployment is accurate.

21 At this level of the organisation there would be fewer

22 opportunities for redeployment.

23 MR SHELDON: They know how many people are going to get

24 sacked but do not know what is going to happen to them.

25 MR KOUSOULOU: What this was alerting people to was there

48



1 were limited redeployment opportunities for these

2 members of staff and that was an accurate position.

3 MR SHELDON: 178.516 volume 28A please. This is the memo we

4 glanced at before which was copied to you on 24th June,

5 about nine days after that meeting. This is from all

6 the staff at North Tottenham:

7 "... writing to express our dismay and distress at

8 the proposals being made to restructure this department,

9 proposals that we believe to be unnecessary,

10 short-sighted and potentially dangerous for the people

11 to whom we offer a service."

12 Two separate points being made. Staff firstly are

13 extremely unhappy and secondly think it may have

14 a detrimental impact on service provision. You were

15 aware of that at the time?

16 MR KOUSOULOU: Yes.

17 MR SHELDON: Your view was we knew they were not going to

18 like it?

19 MR KOUSOULOU: It was inevitable where job losses were

20 coming into play where the management structure was

21 being changed and much more clearly focused that people

22 would not be happy with those changes.

23 MR SHELDON: Yes. But if I was to suggest to you that the

24 level of dismay and distress was substantially increased

25 by the lack of clear information coming to those people

49



1 whose jobs are in the balance, you would say no they

2 knew the clear structure from the outset, would you?

3 MR KOUSOULOU: My understanding is the structure was clear,

4 that Carol Wilson had extensive discussions within her

5 service about the structure of this part of the

6 organisation, and that the information that was required

7 by the people directly affected was available to them.

8 MR SHELDON: Could you turn to 178.537. This is the day

9 after that memo that we have just looked at saying how

10 distressed and upset people are, from Dave Duncan to

11 senior practitioners within the team for which he was

12 responsible. He says:

13 "At the management meeting on 23rd June

14 Tina Kamilaris presented an up-to-date situation

15 regarding restructuring. It has come as a great

16 surprise to us that senior practitioners are going to be

17 more quickly affected by the restructuring than we had

18 first realised."

19 Further down:

20 "I do realise that what is being proposed is not

21 what has been said to you previously by myself and team

22 managers. We had genuinely believed that senior

23 practitioners' posts would only be altered following

24 natural wastage. I do appreciate how worrying this is

25 for you and I do sympathise."

50



1 So we would appear to have had a fairly radical

2 change, at least if you are one of those six people to

3 whom this memo is directed, a very radical change

4 indeed. That is not a satisfactory way to go about

5 handling your employees, is it?

6 MR KOUSOULOU: It is the first time I have seen this

7 particular bit of correspondence. Tina Kamilaris is

8 a member of staff from the Human Resources Service, so

9 clearly she was attending the meeting to make sure there

10 was an understanding. My reading of this is that the

11 implementation of the revised structure below team

12 managers, which was the senior practitioners, was being

13 brought forward.

14 MR SHELDON: That may have been your understanding but what

15 that document seems to indicate is that Dave Duncan who

16 is supposed to be briefing his staff on this whole

17 process has been side-swiped by somebody coming in from

18 Human Resources to say that perhaps all these senior

19 practitioners' jobs are on the line after all and he is

20 writing to them apologising for the distress this must

21 cause because that is not what they were being told up

22 to then.

23 MR KOUSOULOU: The senior practitioners' jobs were not at

24 risk. The overall number of senior practitioner was

25 actually being increased as part of this process.