The transcripts of the official inquiry into the culture, practices and ethics of the press. More…

  • MR ANDREW EDWARD COULSON (sworn).

  • Your full name, please, Mr Coulson.

  • I ask you to turn up your witness statement, which is dated 1 May of this year. If you look at the last paragraph and underneath it you'll see a signature which is yours, with a date and a statement of truth. The statement of truth is given within the constraints imposed on you by the ongoing police investigation and lack of access to documents; is that right?

  • I'll first of all attempt a short timeline of your career. You started working as a journalist in 1989; is that correct?

  • Between 1994 and 1998, you edited the Bizarre column at the Sun; is that right?

  • The year 2000, you were deputy editor of the News of the World under Rebekah Wade as she then was; is that correct?

  • January 2003 you were appointed editor of the News of the World. On 26 January 2007, you resigned. Around June 2007 -- we'll come to the exact date when you give your evidence -- you were appointed Director of Communications to the Conservative Party; is that right?

  • You started work, I think, on 9 July 2007, and after the last General Election, I think on 12 May 2010, you were appointed Director of Communications at Downing Street; is that correct?

  • And you resigned as Director of Communications on 26 January 2011.

    Can I ask you this general question first of all, Mr Coulson: there are reports about that you have been keeping a personal diary in the style of Mr Alastair Campbell, which might, as it were, be a contemporaneous record of relevant events, particularly between July 2007 and January 2011. Is that correct or not?

  • So in terms of how your witness statement has been prepared, you've had to rely on your memory, self-evidently. Are there any other documents that you've had access to which might have assisted?

  • There were some notes that I would take as I -- you know, in the course of my work, both from opposition and government.

  • So these are manuscript or computer records, are they?

  • Notebooks. And have you had access to those notebooks when you have prepared your statement or not?

  • You have been arrested in connection with Operation Weeting and Operation Elveden, so I will not be asking questions which bear on those matters, do you understand?

    Can I ask you some background questions? It's clear from your statement that you were, perhaps still are, close friends with Rebekah Brooks; is that right?

  • Yes. We haven't spoken for a while for obvious reasons.

  • Can I ask you about the frequency of your interaction, particularly after July 2007. About how often would you speak to her?

  • It would depend. I think I've scheduled the sort of meetings that we had, social meetings that we had, but we would talk now and then. I wouldn't say even that we spoke every week. There were times when we didn't speak for quite some time, but it was -- I'd say that we spoke over that period of time regularly, I think is the word I'd use.

  • Did you communicate by text message with her?

  • And then obviously by mobile phone; is that right?

  • Would it be fair to say that you knew what each other's respective political standpoints were?

  • Well, she knew I worked for the Conservatives, so that was pretty clear. As to her political allegiances, you know, the -- in terms of her period of editorship at the Sun, she was supportive of the Labour Party, and obviously she was chief executive when the Sun then changed its allegiance to the Conservative Party. As to her personal views, her personal beliefs, how she voted, I have no idea.

  • Do you have any insight into her personal political beliefs or not?

  • No, not beyond the odd conversation that we'd had, but I guess the question is, if I might be so bold, how did she vote, I have no idea.

  • Was she someone who you felt was close to certain politicians?

  • Yes, I think through the course of her work she was close to politicians, yes.

  • We'll come to that in a moment. When you took over as editor of the News of the World in 2003, which aspects of the culture there, if any, did you want to change?

  • I don't remember wanting to change any of the cultural aspects. The main change I instigated on becoming editor was a cosmetic one. I wanted to redesign the paper.

  • You've worked at both papers, the Sun and the News of the World. Are there any differences in the culture at those two papers or not, in your view?

  • In so much as one is a daily paper, so the pace of the paper is very different, the atmosphere is different to a degree, certainly on certain days of the week. If you try to find a comparison between the News of the World mood, if you like, and the mood of the Sun, it's on a Saturday obviously because that's the day you're producing the newspaper.

  • Moving to, please, your dealings with Mr Rupert Murdoch as editor, so we're looking now at the period 2003-2007. About how often would you speak with him, do you think?

  • I can't put a number on it, but he would call usually on a Saturday night. Sometimes it would be, you know, maybe a couple of times in a month, sometimes you might go a couple of months without hearing from him. So it was -- I think I would describe that as irregular, and almost always -- in fact, I think always a sort of Saturday night phone call. Aside from the, you know, occasional News International meetings when he was in London or when I would go to New York along with all the other editors for the sort of budget discussions.

  • In terms of the content of the paper, what in particular was he interested in?

  • In terms of the specific content, I don't remember any conversations with him initially about a particular part of the paper. We did talk about the sports pages. The company had made a big investment in expanding the size of the sports pages, sports coverage in the News of the World, and that was a fundamentally important part of the sort of commercial mix of the paper, so we -- I'm sure we discussed that. And we discussed politics generally and he would give me his view on whatever was sort of in the news at the time, maybe.

  • We know Mr Murdoch was interested in football because he tried to buy Manchester United, we know that didn't succeed, but wasn't he interested in things such as scoops and front pages?

  • In those conversations I might tell him, if we had a good story, what we were planning to run that night, but not always, by any measure.

  • Wasn't he interested in stories which might impact on the commercial success, the circulation figures of the newspaper?

  • Well, insofar as -- I mean, sport is a good example. In terms of driving sale of the News of the World, the sport was crucial. And it also had a massive impact on the sort of physical production of the paper, so that was a -- I certainly remember having that conversation. News International invested in some very expensive presses during my time as editor, and I had real concerns that those presses, although very successful in some regards, would impact on the production of the paper, particularly the sports coverage. You wouldn't get the right team's coverage into the right area, for example. I certainly remember discussing that.

  • You're bringing the conversation around to quite neutral topics such at sport. Did he ask you questions directly about circulation figures?

  • He may well have done, yes.

  • And during these sporadic telephone calls, him usually phoning from New York, presumably, on a Saturday, did he tend to ask you, "How's the circulation going"?

  • I certainly remember occasions when he did, but it wasn't the -- I wouldn't want to characterise it as the main purpose of the call, because quite often he wouldn't even mention it.

  • But both you and he were aware of the sort of factors which might impinge on the circulation figures of the paper; is that correct?

  • Yes. My job as editor was to -- was absolutely to produce a successful newspaper.

  • When you said you discussed the political issues of the day, were these quite general discussions about topical issues such as Europe, the European referendum or whatever it might be?

  • Yes. I mean, Europe wasn't as big an issue for the News of the World as perhaps it was for a daily paper like the Sun, but yes.

  • Did you discuss the politicians of the day and how well they were doing in your eyes?

  • Did you have a sense that he wanted to find out how political opinion in this country was moving?

  • I don't recall a sort of specific conversation in that way.

  • But in general, Mr Coulson, I'm not asking you to identify a moment or a particular conversation, but in general did you have any sense of that?

  • I might well in the course of a conversation offer a view, normally related to a particular issue rather than the sort of longer term picture.

  • During this period, 2003, 2007, were you particularly interested in politics or not?

  • And although your paper may not have adopted this position, your own personal position throughout has been pro-Conservative, hasn't it?

  • Well, we supported Labour under my editorship at News of the World.

  • I'm talking about your own personal --

  • I'm not seeking to be so personal as to ask you how did you vote, I just want to seek your general perspective on things. Generally speaking Conservative?

  • Sure, one tends to vote in line with your personal feelings, but yes, I think that's fair to say.

  • Do you feel it was part of your job as editor, perhaps in any event, to assess the political mood of the country and in particular how the country was likely to vote in the next General Election?

  • I think my job as editor was to -- as best I could, to establish where the News of the World readership was in terms of politics and certain issues.

  • No, I think to try and reflect, sir.

  • So in that sense, to follow?

  • Yes, I think there's more follow than lead, I would say. There were some issues that as an editor you would want to champion, and therefore I think probably aim to lead opinion, but I think generally speaking, a successful newspaper is one that's in tune with its readership.

  • So there are some things you can't get them to do, but there are some things you could get them to do if the cause is right?

  • Them as in politicians or the readers?

  • No, I don't think you can get readers to do anything other than try to buy the paper.

  • All right, all right. You have to have an understanding of where they are so that when you decide that you do want to promote a particular cause to go into leadership mode that it is sufficiently in tune with where you know they are that it doesn't cause you trouble.

  • Yes, you want the two to be aligned as much as you possibly can.

  • That's what I was trying to get at.

  • Of course, the exercise tends to be rather unscientific because you have a very large readership, over 3 million people are buying the paper, and obviously a whole range of opinion within that readership; is that right?

  • Do you take opinion polls, even on a rudimentary basis, of what your readership was likely to vote?

  • Pretty rudimentary. There was some market research that I'd occasionally get access to.

  • Would you describe your relationship with Mr Murdoch as being warm or something different?

  • I was an employee and we had a -- I thoroughly enjoyed my time working for him, and in the sort of interactions I had with him, yes, he was warm and supportive.

  • So warm towards you and vice versa, is that it?

  • I wasn't particularly close to him in that regard, I wouldn't want to overstate it. He was supportive to me as an editor and I enjoyed working in his company.

  • There are rumours that you turned down the editorship of the Daily Mirror upon the resignation of Mr Morgan. If you did, that might reflect on your loyalty to Mr Murdoch, but did you?

  • There were conversations, yes, towards the possibility of me becoming the editor of the Daily Mirror, and I chose not to do so.

  • Okay. The one General Election which came in your watch, as it were, was the 2005 election.

  • You say in paragraph 40 of your statement:

    "In the end [you] decided to continue the paper's support of Tony Blair."

    Why "in the end"?

  • Well, it was a sort of long process, really. I had a range of meetings in the sort of lead-up to the election, a conference, an outsider conference and I over time, together with my team at the News of the World, decided in the end that we would continue to support Tony Blair.

  • Did you believe that he would probably win that election?

  • Well, it wasn't the key factor in the decision. The key factor in the decision was -- as I touched on earlier, was I felt that News of the World's readers' best interests would be best served by Tony Blair. But, you know, if you read the leader at the time, I think I -- I think it was -- I don't think it was wildly enthusiastic. But I think on balance we felt that that was the best way to go.

  • You say you reflected the mood of the country I suppose; is that right?

  • Did you take advice about who might win that election?

  • From your political editor, for example?

  • Oh, sorry. In terms of advice, I mean we had a -- some pretty detailed conversations about it, and that would certainly have involved the political staff. I was keen also to involve members of staff who didn't work in politics, who didn't understand Westminster, who weren't immersed in that world, people who worked in different departments on the magazine and in features, and what have you.

  • Did you have discussions with Rebekah Wade about it?

  • No, I don't think so. In terms of the editorship of the Sun, and the editorship of the News of the World, they are separate -- or they were separate papers, and there was a sort of clear line drawn between the two. There's a rivalry, actually, or there was a rivalry between the two. And so I wouldn't have had a -- I certainly don't remember any conversations with Rebekah about that issue.

  • So the Sun's endorsement of the Labour Party would have been a surprise to you then, would it?

  • I don't know if it was a surprise. I certainly didn't play any part in that decision-making.

  • Did you have any discussions with Mr Rupert Murdoch about it?

  • About the Sun's endorsement?

  • No, the News of the World's endorsement.

  • I don't believe I did, no. I may have had a conversation with him after the event, possibly. I don't know. I don't remember, anyway.

  • Wouldn't you, though, have wanted to find out whether what you were doing was contrary to his viewpoint?

  • No. I didn't have a conversation with him, I don't remember one, I don't think it happened, about the 2005 election. I followed my own path with it and I don't feel, you know, sitting here now, that I was pushed or encouraged or certainly told to go a certain way. I remember the process quite well and I was determined that we would spend a reasonable amount of time with politicians from both parties and then we would make up our own minds.

  • I move forward to October 2005, Conservative Party conference. There were five candidates standing for the leadership. You'll recall that, Mr Coulson?

  • You tell us in paragraph 33 of your statement that you met Mr David Cameron there at a dinner hosted by Mr Les Hinton, do you recall?

  • Was he soon your preferred candidate for the leadership?

  • Certainly not at that stage. I've taken the time to look back at some News of the World editions of around that period, and I don't think that the News of the World ever explicitly supported Mr Cameron in the leadership. I don't think we explicitly supported anyone. But we did employ at that stage William Hague as a columnist and I think that Mr Hague expressed a preference, before of course he then went to go and work with him.

  • From your own personal perspective, was he your preferred candidate for the leadership?

  • Not that I recall. I don't think I formed a -- at that stage a clear view. I found a leader, actually, as I was looking at this issue. I found a leader from the News of the World where we suggested that it was his to win, and I think -- I haven't found anything to the contrary -- I think that's as far as it went, so there was a -- we certainly weren't against him, put it that way.

  • Between December 2005 and January 2007, was the News of the World slowly moving towards supporting the Conservative Party at the next election?

  • I don't think so. I mean, it was the News of the World under my editorship that came up with the headline "Hug a hoodie", and I don't think that was especially helpful to Mr Cameron, so I don't think that that's the case.

  • In paragraph 34 of your statement you talk about the agenda for your meetings with politicians at around this time. You make it clear:

    "At no point in any of these conversations was the potential support of the News of the World ... discussed and nor indeed were any commercial issues."

    And by "commercial issues" you presumably mean the direct business or commercial interests of News International, do you?

  • Did you discuss issues which would nonetheless impact on the interests of the press more generally such as conditional fee agreements, appropriate sentencing for breaches of the Data Protection Act, those sort of issues?

  • I don't -- I don't recall doing so, no.

  • Human Rights Act, was that a frequent topic of conversation?

  • That may have come up in conversation. Yes, that's possible.

  • In the context of the Human Rights Act, were you in the camp that freedom of the press was to take precedence over privacy of individuals?

  • I'm certainly a believer in the freedom of the press, yes.

  • So if there were conversations about the Human Rights Act, it's clear what your position would have been during the course of those conversations, isn't it?

  • Well, I'm certainly a believer in the freedom of the press. That much is true.

  • In this same period, December 2005 to January 2007, as regards your dealings with politicians, would it be fair to say that it was a clear subtext of your dealings with senior politicians of all three main parties that they were keen to know whether the News of the World would support them?

  • No. The sort of explicit issue of "will you support us" has never been asked -- was never asked of me during that time directly, no.

  • Clear subtext. That's the way I put it, Mr Coulson.

  • Well, I think that they -- politicians from both sides in those conversations were seeking to get their message across and hope that it would be received by us in a positive light.

  • Usually in human interactions one knows what the other person wants out of one. It's not rocket science, is it? This was the clear subtext of your conversations with politicians, wasn't it?

  • The agenda for me was to work out in the course of a conversation whether or not the party or the -- the politician or the party he represented would best serve the interests of News of the World readers, and I had some ideas as to what kind of constituted that.

  • Do you think the politicians you spoke to knew that you were a Conservative Party supporter?

  • You refer to a conversation with Mr Brown in 2006, Labour Conference Manchester, do you see that? Paragraph 36.

  • If it was at the Labour Conference in Manchester that year, we knew, because it was announced, that Mr Blair would be leaving within the year and therefore in all probability Mr Brown would be the next Prime Minister. Are you with me?

  • I think that was a given, yes.

  • You say:

    "I remember that meeting well because Mr Brown told me he had it on very good authority that Rupert Murdoch would appoint me as editor of the Sun when Rebekah was promoted."

    Do you see that?

  • So he was effectively telling you that it was already Rupert Murdoch's decision, one, that Rebekah Wade would be promoted and that, two, you would be in line to be the next editor of the Sun?

  • That's what he was saying, yes.

  • Why did you take that with a large pinch of salt, as you say?

  • Because I didn't frankly believe that Rupert Murdoch would have had that conversation with him.

  • But why not? He was close to Mr Brown, wasn't he?

  • My understanding of how News International worked in terms of appointments of editors is that he would not have involved a conversation either at that stage, by the way, because it was some time after that that Rebekah was promoted, quite some time after that, and also I just didn't believe it. I just got -- I came away believing that this was an attempt by Mr Brown to sort of impress on me his closeness to Mr Murdoch. And quite frankly, I didn't believe it.

  • It was certainly an attempt by Mr Brown to impress on you his proximity to Mr Murdoch, that's clear, and that was the strong message he was transmitting to you, but his two predictions were right, though, weren't they?

  • His two predictions were right? Well, I didn't become the editor of the Sun. I would say as predictions go it was pretty hopeless.

  • If certain events hadn't intruded then you might have become, but Rebekah was promoted, wasn't she?

  • She was some time later, yes.

  • You refer then to Mr Osborne. You say you met with him in 2005 -- this is paragraph 37.

  • Did you get on well with Mr Osborne?

  • I got on fine. We didn't spend a lot of tim together, but I remember having a cup of coffee with him at that conference.

  • You deal in paragraph 38 specifically with a story which was published in the News of the World in October 2005.

  • You were asked to deal with that in your witness statement and you have done. Can we just understand the context. Was the Sunday Mirror also going to publish the same story?

  • Yes. I'm not sure at what point I was aware the Sunday Mirror were going to publish the story. They did publish the same story, though, yes.

  • On the same Sunday?

  • And you could anticipate that the Sunday Mirror's position would be quite hostile to Mr Osborne, couldn't you?

  • Well, I didn't know that -- I'm not sure that I knew they were publishing it, so I hadn't really given that any thought, but I think it's a given that the Sunday Mirror is a more left-leaning newspaper and so as a consequence may have been more critical of Mr Osborne.

  • But you knew that the Sunday Mirror had the story, you knew logically they could only publish it on a Sunday. In the event, they published it on the same Sunday as the News of the World. It was all pointing to the same date, wasn't it?

  • I'm not sure that I did know -- at what point I knew that the Sunday Mirror had the story.

  • The story, stripped down to its bare essentials, was capable of being harmful to the interests of Mr Osborne self-evidently, wasn't it?

  • It certainly wasn't helpful.

  • Your editorial slant on the story was favourable, though, to Mr Osborne, wasn't it? If you look at what you said, it's under your tab 3, our page 02395. We're on now 18 October 2005. The story itself is splashed over three pages and contains all sorts of detail I don't think it's necessary for us to go into now, but of course it's there if anybody want to read it. But you were effectively saying that Mr Osborne should be given another chance, weren't you?

  • I think the leader was saying that "Here's the information, here's what he says about it, make up your own minds". I think if I were to try and distill the message of the leader, "Tories' fate is in your hands", that's how I would distill it. But Mr Jay, I would say this: that's the leader column of the News of the World and as much as I would love to say that the leaders that I wrote were the most read part of the News of the World, I think I can safely say that they weren't. The front page, "Top Tory, coke and the hooker" I don't think in any way can be described as career enhancing for George Osbourne and the idea that we somehow or other went easy on him I think is ridiculous when you look at the paper.

  • Did you personally write this editorial?

  • I think I would have contributed to it. I don't know if I actually wrote it. Quite often the process is that I would have a conversation with another member of staff and they would write it and then I would edit it or offer a view on it. Sometimes I would write them myself.

  • Whether there's any underlying evidential basis to the story is not the purpose of my questions. You do say in about the fifth line of the editorial:

    "Shadow Chancellor George Osborne was a young man when he found himself caught up in this murky world."

    Do you see that?

  • Then you say a bit later on:

    "Last week we said that the Tory leadership is Cameron's for the taking. Nothing published since then has made us change our mind."

    And of course Mr Osborne was going to be Mr Cameron's number two effectively as Shadow Chancellor and then, in the events which happened, Chancellor of the Exchequer, wasn't he?

  • So this was putting a favourable gloss on quite a murky world, wasn't it?

  • It was a view. It was the paper's view. And Mr Osborne -- again, I am not -- I agree, I don't think we should necessarily go into the detail of the story, but Mr Osborne was not admitting to anything. These were the claims of someone who was a friend of a friend, as I seem to remember, so that was the view formed. I think probably as a result of a discussion with my team, that's where we ended up.

    And I think it also -- I've taken the time to look at the Sunday Mirror's leader. Their leader does not call for Mr Osborne to be fired. It stops well short of that. I think it's fair to say that it's a bit more critical, as you'd possibly expect, but it certainly doesn't suggest that it would be the end of his political career by any measure.

  • Wasn't this a classic example, let me put it in these terms. The News of the World couldn't resist the scoop. It was, after all, in the eyes of the News of the World a great story, so we're going to publish it for what it is, but then let's gloss it in the editorial and put perhaps the most favourable interpretation that could be put on the story. Is that fair or not?

  • I don't think it is and I just think if you're looking for an example of the News of the World being helpful to the Conservative Party, this is, with the greatest of respect, a pretty poor example. What matters here is what's on the front page and what the headline is on pages 4 and 5.

    As I look at this front page now, I'm reminded that, had we not had a DVD promotion that day, this story would have been twice the size, and that's -- you know, that's all I can say. Compare that to the leader column. I just don't think that holds.

  • Would you have buried the story altogether if you knew the Mirror were not going to splash it?

  • Yes, the free DVD was all about Little Britain. That takes up half the front page. We can see the other half. It's a standard News of the World splash, isn't it?

  • I don't think it's standard, necessarily, but it was a News of the World story. It was also a Sunday Mirror story and I think I'm right in saying that other newspapers followed it subsequently. It still gets a reasonable amount of coverage in the Guardian.

  • I think I've taken that point as far as it can go, Mr Coulson. January 2007, you resign. Were there any discussions with Mr Hinton before your resignation?

  • Well, there was the conversation about my resignation, yes.

  • Did you have any discussions with Mr Murdoch before you resigned or not?

  • You've included your severance agreement, which is under AEC1, described as a compromise agreement. The narrative starts at page 02379. We can see it's dated 26 February 2007. Do you see that, Mr Coulson?

  • Which I think is exactly a month after you resigned; is that right?

  • Yes. I resigned two weeks before I actually left. So I resigned -- that conversation that I mentioned with Les Hinton took place two weeks before I actually left the building.

  • So you weren't resigning on the basis that you would walk away from any contractual benefits you might attain, you were resigning on the basis that you would leave consensually, is that fair?

  • Yes. Well, it was my decision. There wasn't a sort of negotiation or a discussion about whether or not I would or I wouldn't. I went to see Les Hinton and I was very clear that I was going to resign, and then I did so.

  • Under clause 3, 02380, you received both payment in lieu of the employer's contractual notice period and compensation for termination of employment, so there are two separate tranches, aren't there?

  • The last tranche is going to be paid in November 2007. From your own experience, was that standard practice or not in severance agreements of this sort?

  • Well, I'd never resigned before, so I don't know whether or not this is the format that was followed, personally. I'm told that the sort of separating out of payments in this way is a reasonably standard practice, but I'm not an employment lawyer so I can't be certain of that.

  • There's reference in the agreement, if you look at clause 4.2, 02381, it's quite a complicated clause but it effectively means that the restricted stock units which were going to vest in you in August 2007 would continue to vest in you notwithstanding your resignation, do you see that?

  • As at that stage, did you also have stock in News International as opposed to News Corporation?

  • I had shares in News International, which I think I sold before I left the company, before I resigned, and there may have been some shares I had around this time that I sold immediately on leaving.

  • Can I be clear, apart from the restricted stock units which were going to vest in you in August 2007, were there any other shares or stocks either in News International or in News Corporation, say, by May 2007, in your possession?

  • I don't believe so, no. No.

  • In clause 4.6 there is the provision that the employer will pay any reasonable professional costs and expenses properly incurred by you in relation to certain matters. That clause, I think, is subject to litigation in the Court of Appeal, isn't it?

  • The last clause, under clause 7.1(b), this is 02382, you agreed that in consideration of a small payment you will:

    "... not make or cause to be made, directly or indirectly, any statement or comment to any person (including, without limitation, to the press or any other media) which might injure, damage or impugn the good name, reputation or character of the employer, any of its newspapers and/or any associated company (including any of its or their directors, officers, employees or shareholders)."

    Has that provision in any way impacted on the evidence you're giving us?

  • Do you know what it means?

  • Okay. When you resigned as editor of the News of the World, did you receive any commiserations from Mr Blair?

  • Yes, sometimes later, yes.

  • I don't remember doing so, no.

  • You were approached by Mr Osborne in March 2007. This is paragraph 29 of your statement. Our page 02412. Paragraph 29, Mr Coulson.

  • You met for a drink and he asked you in effect whether you would be interested in joining the team. It goes without saying that Mr Osborne knew that your natural sympathies were with the Conservative Party?

  • I don't know, you'd have to ask Mr Osborne what his thinking was, but certainly he approached me with the view that I could be a positive asset rather than a negative one, I'm sure.

  • I think it's pretty obvious that he did know, otherwise he would have gone to someone else, wouldn't he?

  • Well, in any event, he was correct.

  • At that stage did you know if anybody else was in the running for the job?

  • At any later stage, did you know whether anybody else was in the running for the job?

  • No. At a later stage, after I'd started working for the Conservatives, I was told that there had been another journalist, a BBC journalist, who had been -- had had a discussion, I think with Mr Cameron, quite some time before I was considered for the job, and for whatever reason that didn't work out.

  • So this is the journalist whose name has come up in this context, isn't it?

  • What did Mr Osborne say that you could offer the Conservative Party?

  • The conversation really was more around my views of how the party should organise its communications in advance of a General Election. Of course, we had no idea at that stage when the election might be. And so I gave my views.

  • What did you tell him?

  • I told him that my view of communications was that it needed to be first and foremost professional, that we needed to have good relationships with as many media representatives as possible right across the spectrum, and I also told him in that conversation and again later in a conversation with Mr Cameron that my firm belief was that television would play a crucial part in any General Election campaign. My view was more so than it had done previously.

  • You had no political experience, did you?

  • You'd never been a political editor of any newspaper, had you?

  • Didn't Mr Osborne at least indicate what he thought or the Conservative Party thought you might bring to the table?

  • I think I was the editor of a national newspaper. I'd been in newspapers for a long time. I had managed a team, motivated a team. I'd kind of, you know, had a hand in running a business, I suppose, in terms of the commercial aspects of the newspaper. As I say, not forensically, that was the managing editor's job, but I had oversight of it. So I'm sure those were considerations.

  • But all those considerations would demonstrate, as I'm sure was the case, that you were a good editor, but that's not what we're talking about here. We're talking about you being Director of Communications for the Conservative Party in Opposition. What qualities did he say, if any, you might bring to the table?

  • I don't know. I don't want to be obstructive, but I think that's going to be a question for Mr Osborne. I didn't -- the conversation was not, "Andy, here's why we think you're going to be great". I don't recall it that way at all. The conversation was very much, "What do you think we need to do to get elected?"

  • It was in part an interview, but at what point did he say, "Are you interested in this job"?

  • In truth it didn't feel like an interview at all. I think it was clear from the off that they were interested in hiring me.

  • And he said that they were going to make changes to the professional set-up and that -- and that he would like me to meet Mr Cameron.

  • So he'd already identified you as the man the Conservative Party wanted, hadn't he?

  • Well, I don't think he would have called me unless I was at the very least on the list. And I had no idea at that point --

  • This might have been an interview, it might have been "Let's see what Mr Coulson's like, let's ask him a few questions and we'll go away and think about it". It doesn't appear to have been like that though, Mr Coulson, does it?

  • We'd met a couple of times previously. Look I don't know what was in George Osborne's mind --

  • Let's forget anything about Mr Osborne. Let's think about you. You're a newspaper man. You're used to selling ideas, selling stories. Did you not see this conversation as selling yourself? That's what most people do in interviews, isn't it?

  • Well, I wasn't going into it as an interview. Actually I went into it, sir, with a degree of reluctance. So I wasn't really thinking about politics until I got the call.

  • Once you met him and it was abundantly clear what they were talking about, how did you put your view across to them that actually it might be a good idea for them to offer you a job? Or maybe you didn't?

  • In the way I that I described, I gave an outline in the conversation with Mr Osborne as to what I felt from my experience in the media the party needed to do to give itself the best chance to be elected. That conversation touched on the print media, of course, because that's my experience, but I remember very well saying to Mr Osborne and later to Mr Cameron that television is going to be hugely important. By the way, hardly a stunning observation, but one that I was very clear in my mind and I was already thinking at that stage about the possibility of TV debates as well.

  • Did it not occur to you, you say you became more intrigued as the conversation went on, and presumably you went away to think about it. Did it not occur to you: "Why are they asking me to do this job"?

  • Possibly it did. But once that first conversation was under way, Mr Osborne said, "I want you to meet with -- talk to and meet with Mr Cameron", and then the process sort of went on from there.

  • But you're entering terrain which is rather different from 17, 18 years of career. Career in journalism, you end up as an editor of the largest circulation newspaper in the United Kingdom, in the English-speaking world, and now you're asked to do something completely different. Doesn't it pass through your mind: "Why are they asking me to do this"?

  • Well, something completely different. I'd been the editor of a national newspaper for a number of years. That involved politics, as we've discussed. And beyond the sort of stories that you've alighted on, Mr Jay. You know, I was dealing in issues. I ran campaigns. I was -- I hope, at least aimed to be -- in tune with the readership of a newspaper that is vast -- or was vast. And I think those things, I'm sure, were attractive.

    If I can add, the route from journalism to politics, you know, I was hardly the pioneer. There had been several people through the history of politics who had gone from newspapers into politics.

  • Yes. Mr Alastair Campbell, of course, had been political editor of the Daily Mirror, I believe, and then became Director of Communications. That may or may not have been a more natural pathway, but you didn't enjoy that previous sort of career, did you?

  • No, but one might argue that an editor of a newspaper going into politics is as appropriate.

  • What about your connections to News International? Did Mr Osborne mention those?

  • I don't remember that being a specific conversation at that point, no.

  • Thinking about it --

  • There may well have been a conversation about, you know, the fact that I worked on the News of the World and maybe we discussed some individuals in that regard. I don't really remember, but I'm sure that the conversation would have touched on my previous employers in some way.

  • It was the elephant in the room, wasn't it?

  • You were close to Mrs Brooks -- or Ms Wade as she then was, weren't you?

  • You had, you've told us, a warm relationship with Mr Murdoch.

  • As an editor and employer, yes. It didn't go beyond that.

  • Mr Osborne, the Conservative Party knew all of that, didn't they?

  • You also, if I can put it sort of empathetically, understood the viewpoint of the sort of floating voter which would be particularly interesting to the Conservative Party?

  • That may have been a consideration, yes.

  • But all these considerations were ones which certainly passed through your mind, didn't they?

  • They may well have done and they may well have done for Mr Osborne.

  • They did, didn't they?

  • I can't tell you what Mr Osborne was thinking. In terms of my thinking, I, as I say, went into the meeting, I didn't see it as an interview. It was a meeting with George Osborne, and my initial reaction to it was frankly slightly reluctant but I was intrigued and I had further conversations and then over time decided that, yes, this is something that I wanted to do.

  • Okay. There were further conversations, as paragraph 30 of your statement makes clear. I just want to ask you this simple question: did either Francis Maude or Ed Llewellyn raise the issue of the Goodman/Mulcaire case with you?

  • I don't remember but it's possible.

  • You say at the end of paragraph 30 that towards the end of May 2007 they, that's the conversations, were restarted and after further conversations with Mr Cameron and others you were offered the job of Director of Communications and Planning.

    Can I just understand the timing in the context of the last question I asked you? Were you offered the job after the conversation which might have taken place with Mr Maude and Mr Llewellyn? Can you remember that?

  • I think the conversation with Mr Cameron in May was -- I considered in my mind to be the confirmation that I was taking the job. It may well be in those conversations leading to that that the process of my joining -- you know, perhaps even an offer letter, I can't remember, or the terms were discussed in advance, but in my mind, that conversation when I was on holiday in Cornwall was the sort of confirmation.

  • You say in paragraph 31 of your statement -- this is the conversation you've just been referring to:

    "He [that's Mr Cameron] also asked me about the Clive Goodman case."

    Can you remember the gist of your answer?

  • I was able to repeat what I'd said publicly, that I knew nothing about the Clive Goodman and Glenn Mulcaire case in terms of what they did.

  • Did the formal job offer follow that conversation on the mobile phone with you in Cornwall and Mr Cameron wherever he was?

  • In terms of paperwork, in terms of the offer letter and when it was a contract signed, I can't remember the exact timing. I think it was afterwards.

  • Can I ask you about the timing of your conversations with Rebekah Wade as she was, paragraph 32 of your statement.

  • You say:

    "At some point I told her and other close friends [you were] in discussion with the Conservatives."

    Might that have been in May or earlier?

  • I can't remember the timing but I know I told my -- a close group of friends, small number of friends, and I'm sure that Rebekah was among them, that I was going to take this job.

  • What was her reaction?

  • I think she would have congratulated me.

  • Was she pleased or not, do you think?

  • I think so, yes. I certainly don't remember her saying otherwise.

  • Do you know whether she had any influence or otherwise over you getting the job?

  • Not that I can recall, no.

  • Were there any conversations with her at any stage which you had with her which might have indicated that she had an influence over you getting the job?

  • No, not that I can remember.

  • Could I just go back? You say that you met Mr Cameron and there isn't a trap or a trick in the question I'm asking, I'm just keen to understand it. You didn't appreciate when you started to chat to Mr Osborne that this was an interview, but by the time you were going to meet Mr Cameron, you knew exactly what was happening?

  • I'm going back to the question I asked before: did you formulate in your mind and did you have to explain what it was that you were bringing to, if you like, the party? What skills you actually could bring to the party? Did you sell yourself to him?

  • I'm sure I tried to talk in the most favourable light for myself, without sitting there and being an appalling bighead. I'm sure I tried to -- in the conversation I would have tried to impress on him that I could do a good job, yes.

  • What I'm keen to understand is what it was that you were able to point to in your history makeup, and I understand the problem about boasting, being bigheaded, I understand that, but to demonstrate that actually this could be a sensible move for them? What was it?

  • Well, I think it's my broad experience and my experience went across from 1998 when I stopped working as a showbusiness reporter, I was involved across the paper in all manner of -- both the Sun and the News of the World, and indeed I'd worked for nine months on the Internet launching a whole series of websites. So I may well have mentioned that, and I think through the conversation they may well have been -- I wasn't necessarily aware of it, but they may well have been trying to tease out whether or not I was the right man for the job and that conversation may well have gone to my background and where I grew up and those kind of things. That's more than possible.

  • Paragraph 42 now, please, Mr Coulson. You say:

    "Whilst my News International background may have been considered useful by the Conservatives when considering me for the post, it was not specifically discussed as being an advantage."

    So that's your best recollection, is it?

  • It is my best recollection, and as I think I've put in my statement, I do remember explaining that my News International background -- this was not suggested by either Mr Osborne or Mr Cameron, this was introduced into the conversation by me -- that my News International background should not therefore be seen as some sort of, you know, a guarantee of the support of either of those papers.

  • Plainly it couldn't be a guarantee, but it might be a factor, mightn't it?

  • Well, my experience might help in terms of connecting with News of the World readers and connecting with Sun readers, yes.

  • And also your personal connections, they would help, wouldn't they?

  • Well, they wouldn't hurt, but I don't take the view that -- and I certainly didn't ever express the view that they would, as I say, guarantee any kind of support.

  • I'm not talking about you expressing a view, nor am I talking about guarantee. What I'm saying is that your personal connections would help, wouldn't they?

  • They would, and my personal connections went well beyond News International.

  • Was it your assessment that at about this time Mrs Brooks was becoming a very influential figure?

  • I would say she was pretty influential before that.

  • Okay. An even more influential figure?

  • Quite possibly. I don't know where she was in terms of her career precisely at that moment.

  • She was still editor of the Sun, wasn't she?

  • Still editor of the Sun.

  • Her star was in the ascendant, wasn't it?

  • I wasn't there any more, but I think that's fair to say, yes.

  • Politicians were very keen to get close to her, weren't they?

  • I think that is fair to say, that they wanted to get their message across to the Sun, I'm sure. Politicians from all parties.

  • But in order --

  • In order to get your message across to the Sun, the best lightning rod was Mrs Brooks, wasn't she?

  • I think if you're a politician, you have the opportunity to talk to an editor, you will take it and you'll attempt to sell yourself and your party in the best possible light.

  • She of course was then and no doubt still is a very powerful personality. Is that your assessment?

  • She's a strong personality.

  • Very powerful personality?

  • I think I'd say strong personality. I don't know about power.

  • Vis-a-vis the News of the World, you explained to Mr Cameron -- I'm sure he understood this anyway -- that you wouldn't get an easy ride from that paper because Mr Myler, the then editor, was more sympathetic to the Labour Party, is that the gist of it?

  • Yes. I don't want to overstate this, but I never worked with Mr Myler so I couldn't say with any degree of certainty, but certainly from what I knew of him, and I knew him sort of briefly, he worked for another Rupert Murdoch paper in New York and we would see each other occasionally at conferences, but his background was with Mirror Group and my understanding through mutual friends and through conversations with him was that he was more likely to be left-leaning. I don't want to suggest that that would necessarily impact on the decisions he was making, but that was my sense.

  • So in early discussions with Mr Cameron, where you were discussing likely support of different newspapers for the Conservative Party, the message you were getting across to him was that the News of the World certainly wasn't in the bag because Mr Myler was not onside, is that fair?

  • I'm not sure I used those words, but I think that was the sort of essence, yes.

  • The premise of the conversation was that Mr Cameron was interested to know how the News of the World might go at the next election in terms of the support it offered; is that right?

  • Well, with regard to this conversation, as I said earlier, I think this is a conversation that I instigated. I'm not sure that David Cameron ever said to me, "Have we got the News of the World in the bag, Andy?" I think this is a conversation that I introduced.

  • And the reason why you introduced it is that you felt that Mr Cameron might benefit from your insights? Correct?

  • No, the conversation went further and we discussed other newspapers as well.

  • Certainly. It's not just the News of the World, it's the Sun, because as you say, also in paragraph 42:

    "I told David Cameron, in one of our first discussions, that he should not" -- sorry, that's the News of the World.

    "Mr Cameron knew Rebekah Brooks and I were friends, but again I made clear, and he understood, that this did not mean that the Sun would endorse us."

    So again the premise of the conversation was, or the interest from Mr Cameron perhaps for you was: how would you the Sun go in the next election?

  • Yes, but as I say, I started that conversation.

  • The Sun in particular was of interest to Mr Cameron, wasn't it?

  • Why do you think that was?

  • Not just circulation. It contains a significant number of so-called floating voters, doesn't it?

  • Within its circulation, yes. Sorry.

  • So in terms of the most important newspaper, if you had to identify one, whose support a political party might wish to attain, the Sun would always be top of the tree, wouldn't it?

  • If you wanted to look at it in terms of circulation, yes, because it has the biggest circulation, but I took a view that there were a number of other newspapers that we needed to work hard to gain the support of and circulation wasn't -- I didn't -- I didn't look at my working day and analyse it based on circulation. I put a lot of effort into trying to secure the support of the Sun. I did exactly same to the Daily Mail. I put a lot of time and work into the Daily Telegraph and other newspapers too.

  • I'm not sure I was suggesting that you would lavish all your efforts on the Sun to the extent you would ignore all the others. All I was suggesting was that the Sun was the most important. Are we in agreement or not?

  • In terms of circulation, yes.

  • In terms of influence on the floating voter?

  • I don't know. I'm not sure I necessarily buy the theory that a newspaper's endorsement will influence its readers directly in that way.

  • Do you think politicians buy into that theory?

  • I think that is a theory that is becoming less and less popular amongst politicians.

  • Yes, but in the times we're talking about, the run-up to the 2010 election, is it a theory do you think the politicians were still buying into?

  • I think that we wanted the support of the Sun. We wanted the support of as many newspapers as we possibly could, and we didn't know when the election was going to be, and so work had to be put into that.

    Can I just make a point that I touched on earlier? Newspapers were not the only focus, by any measure, of our communications. Television was fundamentally important and we were clear that television was fundamentally important to us from the off.

  • That's as a mechanism for communication.

  • Television was going to be bound to have to be impartial.

  • Whereas newspapers don't have that limitation.

  • No, sure, and there are -- you know, the conversations that you have with a newspaper are different to the conversations that you'd have with the BBC, for example, but in terms of planning a strategy, you know, and the people that you wanted to try and have good relationships with, the people that you would spend your time talking to, where you would try and explain and give the best possible light to your policies, television was crucial for that. As crucial, I would say, as newspapers, and in fact as we got closer to the General Election I would say even more so.

  • Planning your strategy in relation to the print media -- put the broadcast media to one side -- were there not two key elements to this? First of all, you had to do your best to secure the support of the Sun in due course, are we agreed?

  • That was certainly an aim.

  • In order to secure the support of the Sun, the best way in, as it were, the best entree, was Rebekah Brooks, are we also agreed?

  • Whilst Rebekah was editor of the Sun?

  • I wouldn't describe it in that way. I was keen actually that we had good relationships throughout -- as much as we could throughout the paper. Same goes for -- if I can keep adding this -- for other newspapers. It is not -- newspapers don't work that way. You know, you can't rely on a call to an editor to guarantee anything, and nor should you. What you were attempting to do was build a series of relationships where when you had something positive to say you would give yourself the best possible chance of getting the best possible coverage, and so it was actually a range of relationships throughout all the newspapers.

  • Certainly. You would not wish to ignore any particular newspaper, even those you felt were, as it were, lost causes. You even mention the Guardian, don't you, at one point in your evidence?

  • That's right. I think the party had very good relationships with the Guardian. I think I probably wouldn't include the Daily Mirror, in truth, or the Sunday Mirror. I doesn't put an awful lot of effort into either of those papers, although we met and we talked, actually. But yes, I -- and more importantly David Cameron -- took the view that we had to talk to as many people as possible. The Tories had a -- the party had an electoral mountain to climb, it was of historic proportions. So we wanted to touch as many readerships as we possibly could and get our message across as far and wide as we could.

  • Did you advise Mr Cameron that it was essential that he became as close as he could to Mrs Brooks?

  • Or did he work that out anyway?

  • There was a family connection. She was a constituent. Charlie Brooks is a constituent of his, so they live relatively close to his constituency home, but there was, I think, a fairly long-established family connection, and I think that was the genesis of it.

  • May I ask you about two perceptions. I think we covered one of them, namely whether influential papers have a hand in the outcome of elections and you've given your evidence on that. What about this second perception, that there's an implied trade-off for support. It might not be the furnishing of direct commercial favours, it might well be the dissemination of a more favourable climate on issues and policies relevant to the media. Do you think there's any validity in that, at least on the level of perception?

  • I don't, really. I think that there's -- in the course of a -- in the course of the election campaign there are issues that a whole range of newspapers would consider to be important to them and where our policies overlapped with those newspapers' campaigns or aims, I would seek to maximise that. But then once in government, you get on with the business of governing and obviously politicians set out to keep their promises, so if you've in the course of those campaigns given certain promises, you do your best to keep them. Of course, we ended up with a Coalition government that made that a more complex process, but --

  • The Prime Minister said in July 2011 words to the effect that "We all got too close to News International". You probably recall that, Mr Coulson, don't you?

  • Is that a view he expressed to you before July 2011, in particular before you left, which I think was in January 2011?

  • No, I don't remember him doing so.

  • You said in your statement words the effect you almost had to persuade him to meet with journalists because it was so important, but you think he probably would have preferred to be doing other work or enjoying a night at home with his family. This is paragraph 78. Did he ever express disgruntlement to you that he had to spend so much time with journalists and editors as part and parcel of the job, as it were?

  • Was it ever in the context not merely is this subtracting from my quality time with my family, but there's a deeper problem here, the perception of getting too close to one newspaper group or perhaps more than one newspaper group? Were there discussions in that sort of frank way?

  • It follows then that you must have been surprised when he said publicly in July 2011, "We all got too close to News International"; is that right?

  • I don't know if I was surprised. I mean, it came after a chain of events. I don't know what his thinking was behind it. I wasn't there.

  • But ignoring what his thinking was, just asking you what your thinking is or was, do you feel that politicians got too close to News International or not?

  • I look at it from the perspective of whether or not there was improper conversations or a deal done, which I think is all part of this sort of grand conspiracy that sort of sits over this idea, and I never, as I've said clearly in my statement, I never saw a conversation, was party to a conversation that to my mind was inappropriate in that way.

  • Can I suggest, Mr Coulson, try not to look at this too literally. You remember when Mr Murdoch gave his evidence he denied many, many times there were no express deals, but we're not talking about inappropriate conversations necessarily or express trade-offs. We're talking about something a little bit more subtle. Don't you agree that there is at least the valid basis for the perception that this closeness is unhealthy?

  • The word "unhealthy" I think sort of implies impropriety, and I'm not sure I agree with that. As I sit here now, I've been out of politics for quite some time, I think things are going to change, I think things have already changed, and I think actually that process may even have begun while I was there. We were the first government ever to be transparent with the meetings that we were having with the media, so maybe that process had already started to kind of enter into people's minds.

  • I think the transparency wasn't introduced until July 2011, but we'll be hearing evidence about that in due course.

  • I'm not sure that's right, Mr Jay, with respect. I think that we made public some special adviser meetings with the media while I was still there.

  • So that was in -- that was in 2010.

  • Can I ask you, please, to go back in your statement now to paragraph 45, which is page 02415?

  • Mr Jay, at some stage we ought to have a break.

  • Yes, let's break now.

  • Let's do that. We'll give Mr Coulson a few minutes and the shorthand writer a few minutes. Thank you.

  • (A short break)

  • Mr Coulson, we're on paragraph 45 of your witness statement, the RSUs, which we saw in your compromise agreement.

  • Going to vest in August 2007, and indeed they did presumably vest on that occasion, didn't they?

  • Is this right, Mr Coulson, that when you took up your job I think in June or July 2007, you had no shares or stocks either in News International or News Corporation, but then in August 2007 these restricted stock units vested in you?

  • No, I think there's a first tranche of restricted stock units that were granted to me before I left News International that had already vested and then a second set that were the subject of this compromise agreement then vested in August.

  • Do you know the approximate value of these stocks?

  • I didn't throughout any time in opposition or in government, but in preparation for today I've checked and yes, their gross value is around £40,000. What deductions would come from that, I'm not clear.

  • And are these RSUs saleable on the open market or not?

  • Why do you think you overlooked them?

  • This is by way of explanation, not excuse. My job in opposition was a busy one. My job in government was busier still, and I didn't take the time to pay close attention to my own circumstances in this regard, and I should have done.

  • The more important question might be this: did you discuss their existence with anybody in the Conservative Party or then in government?

  • Did you discuss their existence with any civil servant?

  • Paragraph 48 you deal with your vetting status. Do you happen to know what your vetting status was?

  • I do now. I didn't then.

  • What is it or was it?

  • And that means?

  • I think it means security check.

  • So it's at least a step short of DV, which is developed vetting?

  • Which is the standard vetting, I think, for someone in your position; is that correct?

  • I don't know that that's the case, no.

  • Did you have any unsupervised access to information designated top secret or above?

  • Did you ever attend meetings of the National Security Council?

  • Yes. My understanding, Mr Jay, if I can, is that the SC level allows occasional access to top secret paperwork and also participation in sensitive meetings as well. I believe that's right.

  • Okay. I'm not quite sure I understand what you're saying in paragraph 48 in relation to an incident at Midlands Airport in the autumn of 2010.

  • Are you saying that someone thought that your vetting status was inadequate?

  • Effectively, yes. I think that there was a meeting that involved a discussion about the communications around that issue or incident and the view was formed that I should have been in the meeting but to be in that meeting I would -- my vetting status would need to be changed. I don't know what stage that process had got, because obviously events overtook and I left in January.

  • To be fair to you, these were all matters which it was for government to sort out, not for you?

  • After publication of the piece in the Guardian in July 2009, were any further assurances sought by Mr Cameron or anyone else on his behalf in relation to the Goodman/Mulcaire matter?

  • Between July 2009 and May 2010, if I can get your bearings now, do you recall having discussions with Mr Myler or anyone else at the News of the World as to who they would support at the next election?

  • I don't recall a specific conversation about the likelihood of endorsement, but we certainly would have had conversations with Mr Myler I think around conference time and, as I say, with other newspapers, and the aim from our perspective certainly was to try and secure their endorsement.

  • The means of securing their endorsement, were those means primarily through Mr Myler or through other people as well?

  • As I said earlier, for me it was about a broad range of relationships, you know, making sure that we maximise the opportunities to get our message across as effectively as we could.

  • I'm talking about News of the World now.

  • Oh, I'm sorry. With the News of the World specifically we had a relationship with the political editor, I knew one of their columnists quite well because I'd hired him onto the paper, and I would talk to him -- not, if you read his columns, that it got me particularly far -- and others kind of on the paper. So we certainly tried to have good relationships.

  • In relation to the Sun you pick this up at paragraph 88, page 02423. You say:

    "I would talk to Rebekah from time to time, when she was both editor of the Sun and later chief executive of News International."

    That of course was in the summer of 2009.

    "Most of these conversations were social although we would on occasions talk about politics."

    And you've self-evidently pursued a pro-Conservative and later pro-government line. Of course that was your job, wasn't it?

  • You knew her very well. When did you sense that she was going to deliver this major prize?

  • I'm not sure that I looked at it as her gift, as you put it, to deliver. And I certainly don't remember a moment at which I thought, you know: great, that's the endorsement secured. I wasn't certain of that fact -- actually, I took the view that I wouldn't be certain of it until I saw it in the paper, but obviously there was the conversation between Mr Cameron and James Murdoch, in which we were told that they would be supporting us.

  • That was on 9 September 2009. You say in paragraph 99, however, 02426, you say:

    "As we approached conference season [that's 2009] the paper's coverage became less positive for Labour."

    So that's something that you would have been tracking, wouldn't you?

  • Yes, I would have been paying attention to it, yes.

  • And you were aware, of course, that Mr Cameron was as it were becoming closer to the Murdochs, you presumably knew about the trip to Santorini in 2008, didn't you?

  • Was that something you had a hand in organising?

  • I may have been involved in the logistics, but I wasn't heavily involved and nor did I go.

  • No. But the fact of his going was something which must have pleased you in many ways; is that right, Mr Coulson?

  • I certainly would have taken the view that it was better to have the conversation than not have the conversation. I didn't form a view that it was in any way a sort of key moment.

  • I'm not sure we're looking for key or fulcral moments which are going to cause immediate tectonic shifts. We're looking at a slow change in approach and in affiliations, but it's one moment along the slide, isn't it, away from Labour and towards the Conservatives, would you agree?

  • We would certainly have hoped so. We would have hoped that it was an opportunity and it was an opportunity for -- I don't know what was said, I wasn't there, but insofar as my view of that meeting, I would have seen it as an opportunity for David Cameron to put himself and the party in the best possible light, but I don't know what happened in the meeting. I don't think we discussed it afterwards. I think he just told me that it went quite well. He went on holiday immediately afterwards and that was that.

  • You knew from past experience that it would take some time to secure the Sun's support since it would come at the right tactical moment from the Sun's perspective in relation to the timing of the next election, didn't you?

  • I didn't know that, no. I didn't get involved in the Sun's decision on the timing and frankly, had I done, I would have wanted it to come as a positive endorsement of the Conservatives in our conference.

  • I'm not sure that was quite the question. Maybe I phrased the question badly. You knew that it would take time to secure's the Sun's support, didn't you?

  • You knew that it would from past experience, didn't you?

  • Yes, I certainly saw it as a long process, but remember, during my time working for Conservatives, there were ups and downs, to say the least, and so did I have a plan that went to that date in Gordon Brown's conference? No, I didn't, because there were periods where we didn't know when the election was going to be. So through 2007 and 2008, the Sun remained at times sort of doggedly supportive of Gordon Brown. So in that regard it was certainly clear to me that it was going to be a long process.

  • But didn't you know that it was also the Sun's strategy or likely to be their strategy to deliver this major prize at the appropriate time from its perspective, which would be as close to the next election as possible?

  • I'm not sure when I knew that they were going to do it on that day --

  • I'm not talking about the particular day.

  • I'm talking more generally. I'm talking about what the Sun said --

  • Would it be a big moment for the Sun if they switched to the Tories? I think that's fair to say. Although I would add, if I can, that in terms of shocks, when you look at the political history of the Sun, the far bigger shock was them bagging Tony Blair. Actually returning to the Conservatives in a way you could argue was less of a shock.

  • You say in paragraph 99:

    "I'm sure I discussed it [that's the coverage becoming less positive for Labour] with Rebekah and with Dominic Mohan."

    So we're now into the summer of 2009, aren't we?

  • Were there frequent discussions with those two about this issue?

  • I don't think I'd describe them as frequent, no.

  • Was Rebekah taking the lead or Dominic Mohan?

  • I think I had conversations with both of them. I wouldn't describe one as taking the lead. Dominic was the editor of the paper and in terms of my attempts to make sure that the coverage for the Conservative Party, coverage of the headlines, what was going into the paper, that's the editor's job, and so I would have had those conversations with him, and indeed other members of his staff.

  • You knew the ultimate decision was going to be made by Mr Murdoch heavily advised by Rebekah Brooks, didn't you?

  • I think I would have taken the view that it would be done -- James Murdoch was now -- had now taken a senior role at News International. I think I probably would have taken the view that it was going to be a combination of views, but obviously Rupert Murdoch would play a part in that.

  • Okay. Three people then. We'll have Rupert Murdoch, James Murdoch and Rebekah Brooks, but they're the three key players here, aren't they?

  • I wasn't party to the conversation so I don't know if anyone else was involved, but I certainly think it's fair to say that the three of them would have been involved and I suspect Dominic would too.

  • But you knew this organisation very well, Mr Coulson. You knew how they operated. You were hired in part because you understood them. Surely you knew that the way in ultimately to Mr Murdoch was through his son and Rebekah Brooks. That was the dynamic, wasn't it?

  • To getting the support of the Sun for the Conservative Party.

  • I think it was certainly an important sort of line of communication for me, yes.

  • The truth is, with respect to him, that Mr Mohan was going to do as he was told, wasn't he?

  • I don't accept that and I don't think I'm in a position to say because I wasn't there. So I don't know what part Dominic played in those conversations.

  • You've worked with Mr Mohan over the years. We've watched him give evidence. If you want a powerful personality, if I may say so, let's look at Rebekah Brooks, but we're not going to find one with Mr Mohan, are we? You know that.

  • I'm not here to give a character assessment on Dominic Mohan. I have no idea what part he played in the conversation.

  • You seem to have a fairly disparaging view of ex-showbusiness reporters, Mr Jay.

  • I'm not talking disparaging. I'm talking about strength of personality, because strength of personality may be part of the picture here?

  • I don't know. I'm not suggesting for a second that conversations with Rebekah were not in any way influential. Yes, I accept that. I also considered my conversations with Dominic, I hope, to have some impact. I didn't have any conversations with James Murdoch, beyond a brief conversation I had with him which I've detailed in my statement when we met briefly for a drink. I certainly didn't have a regular line of communication into him at all.

  • Have you had the opportunity, Mr Coulson, to watch or read what Mr Rupert Murdoch said on the subject of political support, both in relation to the Sun and the News of the World?

  • I've looked at some of it, sir. I can't say I have an encyclopaedic recollection of it.

  • Well, that would be a phenomenal feat of memory. But I'll be corrected if I'm wrong, but in relation to the News of the World, he said that actually the paper that was close to his heart was the Sun and he was really identifying that the Sun's political line was something with which he was involved. Might even be deeply involved. I'm not using his words, I'm using my recollection. Whereas he wasn't quite so interested in the News of the World and he said some observations about that and his lack of interest in that. Did you see that particular part of his evidence?

  • What I'm interested to know is whether that surprised you or surprises you now or whether it fits in with what you experienced at the time.

  • No, I hope I haven't given inadvertently, if I have, the wrong expression here. I'm not for a second suggesting that Rupert Murdoch wasn't a fundamental part of the decision-making process. I'm not suggesting that at all. What I am saying is that from the point of view of my interaction, yes, I spoke to Rebekah, yes, I spoke to Dominic, and I didn't have those -- to use the example of Dominic, I didn't have those conversations in the belief that they didn't matter. I believe that they did matter, and I -- but I wasn't party to that -- a meeting or the discussions that took place at News International that led to the decision. I don't know who was involved. I'm sure that Rupert Murdoch was and I'm sure that Rupert Murdoch took a very clear view.

  • Yes. And would you agree with this, that if Mr Murdoch expressed a very clear view, it would require a remarkably robust editor to say, "Well, thank you very much, Mr Murdoch, I'm very interested in that, I'm actually going 180 degrees in the other direction"?

  • It would be a bold move, yes.

  • After the meeting Mr Cameron, Mr James Murdoch, 9 September 2009 at the George, Mr Cameron must have been pretty happy, wasn't he?

  • We had a brief conversation on the phone and, yes, I think it was positive news.

  • Very positive news, wasn't it?

  • It was positive news, but my view was instinctively cautious and I said, "Let's wait and see when it happens and how it happens".

  • Instinctively cautious about everything, Mr Coulson. Unless Mr James Murdoch was going to go back on his word, this was in the bank now, wasn't it?

  • Well, you know, I didn't want to -- in my mind, I wasn't going to see it as an absolute until I'd seen the paper.

  • Did you have no idea at all when the news would break?

  • I'm not sure when I knew precisely when it would break. I certainly didn't play a part in that decision-making, but I can't recall whether or not it was kind of in the ether once the Labour conference had started, it may have been. It may even have been that I had a conversation and was told that it was likely or not. I do remember being at home and seeing the television, Sky News showing the front page, and that was the moment when I felt, because the paper was there, it's happened.

    But as I say in my statement, I'm not for a second suggesting it was a negative. Of course it wasn't. It was a serious positive for us. But in truth, at the risk of sounding ungrateful, I thought that it was -- it was not the front page that I would have -- if I'd had half the influence that people think I had over the Sun, it was not the front page that I would have wanted. Nor was the timing.

  • Rebekah Brooks was busy phoning everybody else, she was trying to get hold of Gordon Brown that evening and failed and spoke to Lord Mandelson. I'm sure she was trying to get hold of you as well, wasn't she?

  • I can't remember if we had a conversation that night. I do think I had a conversation with Dominic, and I think it came after I'd soon the front page on the television. That's my recollection. I can't recall if I had a conversation with Rebekah that night. We certainly I think would have spoken the next day if not that night.

  • Didn't you take any delight in the fact, knowing that the front page itself was more anti-Labour than pro-Conservative, that its timing was rather delicious, namely it went online pretty soon after Gordon Brown's leadership speech at that conference?

  • It had some impact for the Sun newspaper, but my interests were more selfish. I was more interested in the impact on the Conservative Party and I remember very well searching for the pro-Cameron headline in this edition and I think it was in a sub-deck somewhere. So I'm not trying to suggest that I was disappointed. I wasn't disappointed, of course it was a plus that they were moving to the Conservatives, but I would have preferred them to have done it in a different way. And at a different time.

  • What, nearer to the election?

  • No, I'd have liked for them to have done it during our conference.

  • We know there was a certain amount of anger in the Labour Party at this turn of events. Does that surprise you?

  • And the converse would also be the case. There would be satisfaction if not jubilation in the Conservative Party?

  • I certainly wouldn't describe it as jubilation, but it was -- it wasn't a bad day in the office.

  • No. Did you not feel in any way, Mr Coulson, without belittling everything else that you were doing -- and you've told us that you were doing a lot -- that you had secured the major prize, what you'd been employed in May/June 2007 to secure?

  • No, I didn't feel that way at all.

  • Can I ask you, please, about some of the meetings which you have provided details of to us? AEC3, which is going to be tab 4 in that bundle. They're a list of your media meetings in opposition, our page 02397. We can see looking generally at this list that you're seeing everybody, really, including representatives of the broadcast media. Would you agree?

  • On New Year's Eve 2008, there's a party at the Brooks' farm; is that right?

  • We stayed at -- with Rebekah and Charlie Brooks for New Year's Eve, yes.

  • And there was the wedding in June 2009 and then on 30 September 2009 there was dinner. That was the date, I think, that the Sun headline, "Labour's lost it", came out. Do you recall that?

  • And that's at the Osbournes', we can see; is that right?

  • And you've listed everybody who was there, have you?

  • I suppose the mood might not have been universally favourable because we can see who else was there, but I don't know, I can't speak for Sir Harold Evans, what he was saying, but apart from him perhaps everybody else was pretty happy presumably?

  • What we don't see on this list inevitably is all the telephone calls you might have had with people on your mobile or whatever; is that right?

  • Yes. As I look at the guest list of this dinner, I don't want to set a hare running here but that's my recollection of who was there. I don't think anyone else was invited. That's something you might want to double-check with others who were there. I'm pretty sure I'm right about that.

  • If you turn over the page to 02399, we see 5 November 2009, coffee at the City Inn with Fred Michel of News International.

  • "General politics discussion". Can you remember anything more about that?

  • I think it was the first time I met him. So I think it was literally a hello.

  • What did you understand his role to be?

  • The corporate affairs guy for News International.

  • But with what raft of responsibilities?

  • That brief -- that broad, rather. I didn't know whether or not he had a specific brief. Didn't occur to me that he did. He was the new corporate affairs executive in News International that went right across the company.

  • Of course including News Corporation for this purpose; is that right?

  • I don't know what his -- I didn't know then what his or now frankly what his News Corp -- specific News Corp role was. In any event, I viewed him as a News International not a News Corp person.

  • But you understood that he was the European lobbyist, to put it in the vernacular, for the commercial interests of News International, News Corp, didn't you?

  • I'm not sure that I did. I saw him as a corporate affairs executive. I didn't know -- I know that he had a background in European politics, that's what led to the -- his hand in the Aznar meeting. I knew obviously he was French and he spent a lot of time involved in European politics, as I understand it, but beyond that no, I didn't have any real view or information about his role.

  • But what do you understand by the term corporate affairs executive?

  • From my experience it was logistics. Conference, for example, he might have a hand in organising any News International function. He would be involved on sort of broader issues for News International. That's how I would understand. Not involved in editorial.

  • Certainly not, but it's all rather vague, Mr Coulson. He was a pretty high-powered executive, wasn't he?

  • Well, when I met him here, I didn't give any thought to him being especially high-powered. I didn't know -- it was a new set-up at News International after I'd left. James Murdoch was there, there were lots of people there that I didn't know and who I'd never met, so I didn't know precisely where he fitted into the hierarchy. Nor did I ask, I don't think.

  • Did you know whether he was someone who had frequent contact with government ministers or their advisers?

  • Well, I knew that as a corporate affairs person he was likely to sort of take on a role along those lines. Beyond that, no.

  • And with what end or to what end was he taking up that role?

  • I don't -- I don't know. I certainly didn't have any conversations with him that were specific to News International's aims.

  • Apart from this one conversation you see noted here, were there other conversations with him?

  • I've looked at my itineraries in -- well, first of all, let's take it chronologically. As I touched on earlier, he had a hand in the organising of a lunch between David Cameron and the former Spanish Prime Minister.

  • I don't recall whether or not he attended that lunch. And then later in my itineraries, I've noticed another meeting with him, but it had a line put through it. I don't remember it so I'm assuming that got cancelled. However, once in government I do recall talking to him, albeit very briefly, I think in my office. I can't find a formal record of this meeting and it could well be that he was seeing someone else or was in the building with another meeting and popped in, but in any event that was a brief conversation, as I recall it.

  • Before June 2010, did he discuss with you News Corporation's intention to seek to acquire the remaining publicly owned shares in BSkyB?

  • I don't recall any conversation along those lines, no.

  • Are you saying there wasn't such a conversation or are you saying that you don't recall one?

  • I'm saying that I don't recall one.

  • When the bid was announced, was it a surprise to you or not?

  • I'm not sure I knew about it in advance. I would want to go back and look at the business press in advance of it. I don't whether or not -- where the commentary was, whether or not it had been flagged in the papers, where the sort of level of speculation was about it. I seem to remember that there was a fair amount of commentary in advance. I might be wrong about that. That's my recollection.

  • Not something Mrs Brooks discussed with you, was it?

  • No, I don't remember any conversations with Rebekah about it.

  • Going back to Mr Michel, it's paragraph 95 of your statement, 02425. You say you met with him on a few occasions for coffee including one occasion possibly at Number 10. Do you see that?

  • What was he doing there on that occasion, do you remember?

  • I'm sorry, Mr Jay, are you referring to my reference to the possible meeting at Number 10?

  • As I explained earlier, that's the meeting I'm referring to where --

  • This is a lunch, is it?

  • Which is why I'm putting -- I'm sorry, are we talking about the Aznar lunch or the possibility of a meeting in Number 10?

  • I was seeking to clarify which we were talking about.

  • I'm sorry. The possibility of the coffee at Number 10 is the meeting that I discussed, that I explained, obviously badly, previously. The Aznar lunch was in opposition and was at some time prior to that in 2009.

  • At that point, was Mr Aznar involved with News Corporation?

  • Was he on the board of News Corporation?

  • I believe that's right, yes.

  • You say you can't recall but it's possible that Mr Michel attended that lunch?

  • That's your best recollection, you're not sure?

  • Were the affairs of News Corporation discussed at that lunch?

  • No. Not as far as I remember.

  • Can you remember what the discussion was about?

  • The discussion was about Spanish politics and British politics. The lunch took place in the -- I believe it took place in the House of Commons and it was a -- the first time they'd met, I think I'm right in saying, and it was a political conversation.

  • But it was a lunch that Mr Michel organised, it's not one that you organised; is that right?

  • He certainly played a part in it is my recollection, and -- in terms of the logistics of the lunch.

  • Okay. You go to Downing Street in May 2010. I've been asked to put to you this question, Mr Coulson: your salary was cut to £140,000 a year, wasn't it?

  • Did you explore whether it was possible for private donors to top up your salary?

  • I think it's implicit in that answer that your salary was not topped up by private donors?

  • Not by private donors, no. As I say in my statement, there was a notice payment paid to me as part of my Conservative contract.

  • I understand, yes. You've told us about the BSkyB bid. Did you know what Mr Cable's attitude was to the bid before it became clear on 21 December 2010?

  • I don't believe so, no.

  • You don't believe so or --

  • I don't have a specific memory of -- I certainly didn't talk to him about it and if it had been reported that he'd taken a particular view, and that's possible, I suppose, I can't remember the exact chronology, then through that route, yes I may have been aware, but I wasn't involved in the BSkyB bid. Save for my communications role.

  • And of course there was a political storm of sorts on 21 December 2010 and you were naturally involved in that since it impacted on your role; that's right, isn't it?

  • Did you speak to Mr Hunt that day?

  • I don't recall doing so.

  • Did you speak to Mr Hunt about the bid at any stage?

  • I don't recall any conversations with Mr Hunt about BSkyB.

  • Was there ever any conversation with any politician that sought, whether sensibly or not, to gain the benefit of your experience of having worked for News International for the purpose of considering this bid?

  • Not that I remember, sir, no.

  • I've been asked to put this general point to you, going back to when you were editor of the News of the World: had the News of the World ever plugged Sky TV programmes?

  • My experience of that issue is that when there was a promotion, Sky paid a price for it. You know, literally. I mean it was bought as promotional space. That was the main sort of crossover between Sky and the paper.

  • And they paid the same commercial rate as everybody else, did they?

  • Not given a favourable rate?

  • I don't know. I didn't get involved in that.

  • Can we look at AEC4, which is your list of media meetings in government.

  • In your bundle it's tab 5.

  • We can see from that that when the Coalition government is instituted, Mr Cameron invites most of the important players, editors, BBC political editors, et cetera, to Downing Street over the next month or six weeks; that's clear, isn't it?

  • I think Mr Rupert Murdoch didn't happen to be the first, he appears to be the second on this list. Mr Murdoch mentioned that you were there. Not quite sure why or in what context. Could you help us with that?

  • I wasn't in the meeting, but I did see him prior to the meeting and very briefly before the meeting and again very briefly after the meeting, but I wasn't in the meeting itself.

  • There's a lot of fascination about people going in through the back door of Downing Street. Are you able to enlighten us with that at all or is it a complete red herring?

  • No, I think he did come through the back door, as I think Mr Murdoch may have told you. I think that's how it happened under previous administrations and I suspect it kind of happened automatically, I think.

  • Would that be so for all these people? There's a list of back door people and front door people, except those who stand outside the front door and talk from it?

  • I don't know which door these other people came through, sir, to be honest.

  • All right, all right. I have to keep myself entertained, Mr Coulson.

  • Enlighten us on this. There may be absolutely nothing in this point. Is there a system where some people come in one way and other people come in through the front or not?

  • I don't think so. I know there were some parties where guests would arrive through the back because there's a car park through the back so it's a bit easier. In terms of Mr Dacre's meeting, for example, I have no idea which door he came through. Had he asked to come through the back door either for reasons of his own or because he wanted to park his car there, I'm sure that would have happened.

  • In government was it ever part of your role or practice to brief against particular individuals, as has been alleged by, or against some of your predecessors?

  • No. My job was to -- I would certainly brief in terms of politics, but in terms of people's private lives, no, I don't recall ever doing so.

  • I think I'm using the word "brief" in the sort of sense that's quite widely understood, it's a slightly disparaging context, but one can think of various synonyms for "brief" but I think you know what I mean?

  • In my conversations with journalists I certainly wouldn't hide my political views, obviously. That was the purpose of the conversation. But no, I don't believe I did that.

  • In terms of your discharging your responsibilities, your role only is to play with an entirely straight bat, disseminate government policy, inform, make people -- ensure they understand what government is up to, but never seek to spin from time to time, to influence, to cajole, to brief or indulge in any of those sort of slightly murkier activities? Do I have it right?

  • Well, define "brief". I mean, I thought the question -- apologies if I misunderstood -- I thought the question was did I brief against people on a personal basis. I don't believe I did. But -- beyond their politics. But did I have strong views and would I express those views in conversations with journalists about Gordon Brown or Labour politicians, Labour policy, individuals concerned and the stance they were taking? I think I probably would in the same way that I sought to give or articulate as positive a picture possible for the Conservatives, but I don't believe that I did so inappropriately.

  • As an observer of political life in this country over the last 20 years, do you think the sort of things I've been describing, without reference to you of course, are an issue which needs consideration or not?

  • In terms of negative briefing?

  • I think that moment came to a head with the Damian McBride affair, of course when we were in opposition, which resulted in some very personal stories, stories which by the way were published in News International papers, as well as other papers.

  • Okay. Can I ask you, please, about paragraph 53 of your statement. You say in the second sentence that you "got involved in policy only in relation to its likely impact on the media". Do you see that?

  • Do you feel at any stage it might have been an excessive interest in how policy would play out in the media rather than in its intrinsic merits?

  • Possibly. And if anyone was kind of thinking in those terms, I guess it would have been me as the person responsible for communications.

  • Is this a problem which is a significant one or one which is overplayed, in your view?

  • I don't think it's -- I don't think that it's necessarily a significant problem. I think that political parties have to, with the modern media, fight hard to get their message across, and also there's a -- you know, there is a personality aspect in politics that has probably increased over the years. And that therefore requires -- certainly required for me a lot of attention, and you sought to make sure that an authentic view of in particular David Cameron was being sort of expressed through the media. That would require a lot of work.

  • You left Downing Street in January 2011 in circumstances we're not going to discuss, but can I ask you this simple question: did you discuss your departure with Rebekah Brooks or anyone else in News International?

  • If I did, it was after I had resigned. I'm confident of that. You know, I've tried to remember the exact chain of events. As you can possibly appreciate, it was a fairly difficult period and I can't be absolutely sure, but I think that -- I don't think I had -- I told anyone I was resigning until after I'd told the Prime Minister.

  • You were asked to deal with the case of Mr Driscoll, who secured a substantial sum by way of compensation from an employment tribunal. Are you with me?

  • The hearing was after you left News International. The hearing I think was in 2008. Were any arrangements made or were you asked to give evidence on behalf of News International, or the formal respondent was actually NGN Limited, which is News Group Limited?

  • No, I wasn't, which is a matter of considerable regret.

  • Did you have any awareness that the case was going on as it was going on, before its outcome was announced?

  • I'm not sure that I knew about it in advance, but obviously it attracted some media attention once it got under way. I don't think I knew about it in advance of that. I certainly don't have any recollection of knowing about it in advance.

  • And when the media attention arose, did you think: I can give evidence here?

  • No, I was working for the Conservatives at that point and I took the view -- and I've thought about this since, you know, was it the right decision? I don't know. I took the view that it would only make it worse if I then tried to intervene. I certainly didn't have the view that I could sort of impose myself on the hearing at any juncture and I'm not sure that at what point the damaging -- what I considered to be the sort of damaging comments in the judgment were made. I think it's probable that the damaging comments came, obviously because it was the judgment, at the conclusion of the hearing, so by then it was too late anyway.

  • You, of course, appreciate that it's for the parties to the litigation to decide who they want to ask to give evidence but nobody ever came to you?

  • Yes, sir, that's right. I may be wrong about this, but my understanding is that the tribunal themselves do have a process by which they could have asked to talk to me.

  • But it's quite difficult to see why a tribunal should do that in the context of adversarial litigation. In an inquisitorial system such as the Inquiry, that's controlled by the Inquiry, in that context me. But in the normal form of litigation, the parties decide who they call and it would be quite wrong for the judge to decide of his own volition to do so absent very special circumstances. Anyway, but presumably you'd left records behind of your dealings with Mr Driscoll which were accessible?

  • Yes. I think that some of those records formed part of the case. If I can make this point, I've asked News International to furnish me with all the background to this case in terms of witness statements, in terms of my own involvement and anything else, and they've not been able to do so because I'm an ex-employee. So all I have -- and the questions that presumably you're going to ask me -- all I have to work on is the judgment itself and the precis and the extracts of my own emails and letters.

  • Which were referred to in the tribunal's decision, which is under tab 11 of the bundle. The decision is quite intricate, as you're aware, but you've presumably had a chance to study it.

  • There was a complaint first of all by the Arsenal Football Club in relation to a piece News of the World wrote about one of its footballers.

  • That culminated in disciplinary proceedings in October 2005 and a warning. If you look at paragraph 104, which is page 021349, Mr Kuttner, who I think was the managing editor then, was he?

  • Wrote to you by email dated 9 November 2005, so the tribunal had that. The contents of what he wrote are telling.

    "He stated that the situation was not black and white enough to dismiss Matt Driscoll. He went on to state 'of course we could still fire him: and pay the going rate for that. Mike Dunn [he's the man who carried out the disciplinary hearing] tells me Driscoll can't be got shot off?' The decision to give the claimant a first warning, although the outcome of a disciplinary hearing chaired by Mr Dunn, was made by Mr Kuttner, with the agreement of the editor, Mr Coulson."

    Is that as far as you're concerned accurate?

  • It's accurate in terms of what you're reading. It's not accurate in terms of the sort of wider framework of the judgment because those words "can't be got shot of", misspelt here, were directly attributed to me, which is wrong. They are clearly a report of Mike Dunn's words via Mr Kuttner.

  • But isn't that what this says, Mr Coulson? Doesn't it say in the fourth line "Mr Dunn tells me Driscoll can't be shot ..." I think there's some mistake, it should be "got shot of", not "got shot off".

  • "Got shot of", yes. Sorry, my point which may be off your question, in which case apologies, is that the "can't be got shot of" seems to form a fundamental part of the judgment as coming from me, as being my words, and they're not my words.

  • I'm not sure that error is made by the tribunal. I think all they say is the words come from Mr Dunn, but the decision to give the claimant a warning was made by Mr Kuttner with your agreement. Is that correct?

  • The judgment, I think, says that it was a pretext for my desire to "gets shot of" the claimant. I never said that.

  • Okay. Paragraph 105:

    "The claimant felt it was highly unfair for Mr Dunn to have issued him with a warning. He wrote a letter, 10 November 2005, to that effect and copied it to Mr Coulson. He informed him that although he could not accept the criticisms made of them because he believed them to be unfounded, in the interests of harmony he decided not to appeal.

    "Mr Coulson responded to Mr Driscoll's letter. The contents of his response are also very telling. He stated:

    "'I also disagree with the adjudication. In my view your actions on this matter merited dismissal.'"

    Is that what you said?

  • Yes. If I can add again briefly that I'd like to have seen the full letter before I was asked to respond to this. And I've not seen the full letter. All I have to work on is the judgment. And on the basis that -- I don't wish to go on about this, but on the basis that the judgment couldn't even get my quote right, I am therefore not particularly willing to accept their interpretation of it.

  • I think we've already established that what you believe is attributed to you in paragraph 104 is not because it comes from Mr Dunn. Do you see that?

  • I'm referring to the judgment, the later judgment.

  • What they're doing, the tribunal, in paragraph 106 is setting out a direct citation from something you've said which might appear to be somewhat hostile and then to paraphrase what else your letter said:

    "He went on to state [that's you going on to state] that his performance would be monitored closely and that if it did not improve or if there was any repeat of any of the failings, further disciplinary action may be invoked against him. He offered no words of encouragement. In the context of Mr Coulson being the editor of the paper, this was a bullying remark."

    The simple question is: that's a fair point, isn't it?

  • No, I don't accept that. It was a reaction to a letter that he had sent to Mike Dunn and copied to me. I was irritated by it, I will accept, and I will also accept that my response was perhaps intemperate, but I do not accept that it equated to bullying, and in any event, following on from this letter, Matt Driscoll went on to kind of continue in his work in a very kind of positive way. I think that's documented. I think that Mike Dunn wrote to him shortly afterwards with a message that was basically "upwards and onwards" and that was -- that was supported. I was happy to support Mike Dunn in that process.

  • But the tribunal found that wasn't so, that this was the start of a downward path, but I think what is most material is that whereas in formal terms all that Mr Driscoll received was a warning, you were saying, well, he should have been sacked. That's true, isn't it?

  • My view was that the issues that led to the tribunal were serious, and should be taken seriously, and yes, I expressed the view that in my view he perhaps should have lost his job over it, but that didn't happen and I accepted the decision of the tribunal and there was no grudge. I did not at that point, as the tribunal find, decide that that was the end of Mr Driscoll's career at the News of the World. I think that both the tribunal and Mr Driscoll kind of picked different moments as to when they claim I decided this. In another part of I think Mr Driscoll's evidence he says that it started with the story about the Arsenal shirt. Now, if I was making decisions about News of the World staff and their future on the basis of a failure to stand up a tip or a story being lost to another newspaper, three-quarters of the staff would have been on disciplinaries. That's the nature of -- it's part of the cut and thrust of Sunday newspapers. And in any event, it was a story about whether or not Arsenal would be wearing purple shirts. It wasn't an exclusive about who was the next manager of England, for example.

  • Later in 2006, paragraph 130, do you see that?

  • "Mr Wallis [that's a witness we've heard here] reported to Mr Coulson. Mr Coulson's response is instructive. He stated by email to Mr Wallis dated 19 July 2006 he wanted him out as quickly and cheaply as possible."

    Do you remember that email?

  • Inasmuch as I've been reminded of it both through this tribunal and before. Again I've asked for all the emails. So I don't know what the exact context of it was, I don't know what came before or followed afterwards.

  • I think all the tribunal are saying is there was a bit of a pattern here, if you follow me, certainly if you marry up the November 2005 email with the 2006 email it's consistent. You want this man out and reasonably you're bullying him. That's the truth, isn't it?

  • No, it's not the truth. The first point to make is that in between times it was clear that I'd supported Mr Dunn in actually trying to get Mr Driscoll's relationship with the News of the World back on track.

    The other point I would make is that at some time, many months, several months before I sent this email, Mr Driscoll himself had instigated severance negotiations with the paper. So my recollection is that this email, "want him out as quickly and cheaply as possible", is absolutely in relation to that process.

  • Okay. So you disagree with the tribunal's clear findings; is that right?

  • I think that's as far as I can really take that issue, Mr Coulson. Those all the questions I had for you. Was there anything you particularly wanted to say that we might have left out?

  • Can I make one point in relation to the theory that there was some kind of deal between News Corp or News International and the Conservative Party over the issue with BSkyB? Can I just make one very straightforward point?

    If there was a deal, and if there was a conspiracy, as people seem to be suggesting, why was Vince Cable given the job? It is in the Prime Minister's gift to decide who -- of course there was the complex nature of the Coalition, but it was the Prime Minister's gift to decide who held which brief in his Cabinet, so if there was this theory, if there was this conspiracy running that David Cameron was going to somehow or other return the favour to News International, why on earth did he give it to -- and I would choose my words carefully -- a combative member of the Liberal Democrat Party?

  • Of course, Mr Cable was already the business secretary in May 2010, was he not? The BSkyB bid would fall within his province and that wasn't announced until June 2010.

  • No, but the conspiracy, I think, suggests that this was a deal that was done some time before.

  • All right. Well, it's an advocacy point rather than a factual point.

    Can I ask a very different question? You probably as much if not more than anyone else have doubtless reflected on the issue which is at the core of this particular part of the Inquiry, which was, of course, set up by the Prime Minister in July last year. And the issue is whether the relationship between the press and the politicians has become either close or no longer entirely conducive to good government, whichever way you want to put it.

    Now, whether this happened many years ago, whether it's a consequence of the involvement of those who've been very heavily concerned with newspapers into the heart of communications in government, one could debate, but I would like your view on whether that relationship has become too close so that it gets in the way and how that should be addressed, if you have a view on it.

  • Well, the Prime Minister himself has said that he accepts that it got too cosy, and I'm not minded to disagree with him. I think that it's perfectly clear now, as a result of this process, that the relationships with the media have got in the way of the message, let's put it that way. I think that is abundantly clear. What you do about it, I think, is much more difficult because I would hate to think that -- I'm not suggesting that this is on your mind, sir, but I would hate to think that any barriers would be erected, more barriers would be erected between politics or politicians -- politics more importantly, and the press.

    You only have to look at the turnout at last week's local elections which was low, to say the least. People are disengaging with politics. If you make it more difficult for the media to report on politics, if you make it more difficult for journalists to understand what it is you're trying to do, that's going to get an awful lot worse.

    Some people may say that that turnout is because of this Inquiry or because of people's general reaction of what's been reported over the last months. I'm not sure I buy that theory. I come from the perspective of someone who's worked on both sides of the fence and I just sincerely hope, sir, with respect that the result of this part of the Inquiry does not, as I say, erect yet more barriers between what is already a pretty difficult process.

  • If you'd heard what I said earlier today, you would know that I am very keen on ensuring that politicians have a mechanism to identify what their policies are and to seek to engage the public in them, and that journalists have the ability and responsibility to hold politicians and others, in which number I've always included the judiciary, to account for what they do. The question is how to ensure that that happens in an open, transparent and appropriate way.

    It may be you don't have an answer, but if from your experience working both sides of the fence you do have a view -- it's not going to bind me, so you don't need to worry about it -- I'd be interested to hear it. If not, then not.

  • It is incredibly difficult. I mean, one point that troubles me in evidence, if I can say, that's come out throughout this Inquiry, is the idea that a friendship is always based on some ulterior motive. People are friends, people talk to each other and that's certainly true of the overlap between politics and the press.

  • I'm not so sure that's fair, because equally I have said not once but many times that politicians are entitled to be friends with people, journalists are entitled to be friends with people. The question is to differentiate and to be clear about the difference between social relationships and any form of business.

  • Yes, I have to say I think that what's happened over the course of the last couple of years, perhaps over the course of the last year or so, I think is going to solve that problem for you. I think the possibility now of politicians not being transparent about their dealings with the media, I think the events that have come to pass will go a long way to dealing with that.

  • Well, if I could be assured that the very fact of the last seven months had achieved the purpose so that I could go back to productive judicial work, I might be quite pleased with that, but that's a bit of a big leap, isn't it?

  • I wouldn't be so bold as to suggest that, sir.

  • No, all right. All right.

  • Could I just say while Mr Coulson is there that I think what he may have had in mind is paragraph 107 of the tribunal's decision in the Driscoll case because they do there say it was a pretext for Mr Coulson's desire to "get shot of the claimant".

  • I'm sure that's right, but Mr Rhodri Davies, as you know and I know, sometimes judgments don't always spell out all the dots. I take the point, though.

    Mr Coulson, thank you very much indeed.

  • I understand why this has not been an easy process, but there it is. It's been important. Thank you very much.

  • Sir, did you want to hear submissions in relation to Mr Sherborne's application?

  • I certainly do, but I'm not so sure that 4.30 is the right time to hear them. I put them off to today, anticipating that we would be rather speedier than we have been, so are you anticipating being here tomorrow, Mr White?

  • Absolutely. I'm not pressing. We've had a long day and covered a lot of territory.

  • Yes. I think that's probably what we'll do. Does that cause you difficulty, Mr Caplan?

  • No, sir, not at all.

  • I need to address it, in which regard, let me just -- now you're on your feet -- remind you that in relation to one of the points that Mr Sherborne was making about information being stored, it was raised, I apprehend probably as a result of a question suggested to Mr Jay by Mr Sherborne, on Day 37, 6 February, in the afternoon, page 60, line 12, and Mr Dacre said:

    "Let me enquire and come back to you."

    And I'm not sure he has.

  • He hasn't. I'm not sure he was -- it was a number of items were followed up, but can I deal with that tomorrow as well?

  • I noticed the same passage and the questions that were asked.

  • I raise it with you so that you can deal with it.

  • Thank you. Can I just ask, would you be minded to deal with this first thing or later in the morning?

  • Oh, I think that it's probably fairer to the witness tomorrow that we just crack on and that when we've finished the witness, we'll come back to these interesting issues.

  • Thank you very much indeed. 10 o'clock tomorrow morning.

  • (The hearing adjourned until 10 o'clock the following day)