Mark Plant evidence.
BC: Covering email of the QI reports. We see decision to write two reports. Not canvassed with you in advance?
MP: Correct.
BC: Internal report - recommend reading first - honest assessment and detailed recommendations for an in person conversation.
MP: Y
BC: You agree that report contains analysis of specific communications from MF.
MP: Y
BC: Says MP also wanted to show MF a written product, so public facing 'deliberately vague' doc because QI recommendation was not to get into discussion with MF. Recommends caution. You understood her to be saying that the report going to MF deliberately contained no details of specifics that were said to be offensive?
MP: Pause. No detail on the specifics but some indications on why they were offensive.
BC: It reaches conclusion that MF communications did cross the line or almost did in terms of respectful workplace conduct that they recommend action to reset norms. Also there were some posts assessed as disrespectful or borderline?
MP: Y
BC: It did so on basis of review in secret report?
MP: Y
BC: Also 3 other reviews which they describe as independent reviews of social media posts?
MP: Yes.
BC: Relied on those in this vague report?
MP: Y
BC: Identify what those were: external D&I expert - that's QI's own review?
BC: WOuldn't be clear if someone read this (that they were same people)?
MP: Y
BC: Certainly earlier review from Oct 2018 was never shared at this time or any time was it?
MP: N
BC: Second one is the one by external legal counsel - that's Ms S's report?
MP: Y
BC: In fact there was no review in that report, was there?
MP: She had looked at the tweets.
BC: QI say all independent reviews concur that several posts were disrespectful. But that isn't Ms S/s conclusion, is it?
MP: Don't recall.
BC: Third is review by internal fellow. That's Ms Huang?
MP: Believe so. That referred to one tweet but I think she looked at larger set of tweets.
BC: Never shared?
MP: N
BC: Nor was Ms S's?
MP: No
BC: So if no conclusion was reached by Ms S, this is a misleading statement by QI? Hadn't been three independent reviews carried out. (Outlines what actually happened)
MP: Can't remember exactly what Ms S said and Ms Huang had done some work behind the email.
BC: I'm going to suggest that this is sloppy and inattentive work. Is that fair?
MP: There were faults yes.
BC: Do you agree one fault is that they paid little attention to the facts?
MP: N
BC: Did it not strike you as inappropriate and unfair to conclude the MF tweets and comms crossed the line and not give her a chance to respond to any particulars?
MP: N
BC: In retrospect is that not astonishing?
MP: N
BC: Why?
MP: Again, they had one discussion with MF and they had read MF's tweets and the blog, they had read a lot of her work. They were familiar with her work and didn't need to hear more from her.
BC: But what about you? They recommend you send this report to the claimant and then you don't actually discuss any specifics with her? How can that be fair for you to take a decision?
MF: We gave her a chance to respond and she did, so...
BC: Let's unpack answer. They've had the work so they felt they didn't need to speak to her? Lying behind that must be idea that there's nothing the claimant can say in her own defence?
MP: N. Proposition is that the body of work speaks for itself.
BC: Yes, that's what I'm saying. You were accepting of the view that the body of work speaks for itself and there was nothing the claimant could say in her own defence?
MP: I would and did give her a chance to respond.
BC: The other aspect or rationale behind the recommendation not to send MF specifics is QI email: MF knows context of discussion really well and I recommend caution. That is explicitly 'no debate' line, isn't it? There is a view among those who take self-ID position that this is not a legitimate topic for debate at all?
MP: N. Not how I read it. They were saying this is about how to manage the workplace. We should focus on behaviours and not specifics.
BC: They're not talking about beliefs in general, are they? They are saying don't get pulled into the debate on her specific beliefs.
MP: I disagree. They're saying don't get pulled into the debate itself. You're trying to discuss how the claimant can express her beliefs in the workplace. They were pushing me to have a discussion about behaviour in the workplace without going into content of the debate.
BC: But you say in your statement that it suggested I focus the discussion on language and behaviour, not substance.
MP: Y
BC: If you look at p.() you see they are recommending to let her know the topic is language and behaviour is offensive, according to three independent opinions and all agree. You are not interested in looking at each sentence. So even if we accept everything you say as fair, can you explain to me how you can tell the claimant where the line is between offensive and not, without talking about specific language and behaviour?
MP: Um. I mean... I had to make it clear certain things were found offensive and she needed to refrain from discussion of this topic. I was willing to help her express her belief but it couldn't go farther.
BC: You are saying two different things. She should refrain, but she can express her beliefs. You are struggling because you recognise the difficulty of your position. Forget the party line and engage with my questions. I'll put a question: if you are going to say this isn't about a blanket ban, it's about language and behaviour, you have to be able to define the line?
MP: Y
BC: And if it is language and behaviour, not the beliefs, the only way to define the line is to show what goes over it?
MP: Yes
BC: So even on face value fair, the approach QI were urging was a completely inconsistent and ridiculous one? You couldn't explain the line? I'm right?
MP: We tried. I think I did point out some things that were offensive. But I agree, we would have had to articulate this more clearly. We agreed this wouldn't be discussed at work and this probably wasn't tenable.
BC: Helpful. Your ultimate collective position was that there was to be firewall around any mention of her beliefs?
MP: Y
BC: And that is the only time and the only belief were you have ever done this?
MP: Best of knowledge, Y
BC: And we see what underlies it: am I correct in thinking that CGD collectively accepted and sought to apply these QI recommendations?
MP: Only for myself, I tried to apply them as best I could, yes.
BC: You describe their analysis in your statement as 'compelling', yes?
MP: Y
BC: Have you re-read them?
MP: Y
BC: Chance to retract. Do you agree that on reflection they are poor?
MP: I said there were faults.
BC: Back to bundle...