CEP Evidence - Wednesday 23rd September 2020 (1/2)

Full transcript

00:00:12 good morning everyone welcome to today's hearing

00:00:15 hearing today we're going to hear from another witness but from a different company is that right mr miller yes mr chairman good morning we're going to hear from mr jeff blades of cep may i please call mr blades thank you

00:00:42 and truly declare that i affirm that the evidence i shall give shall be the truth the whole truth and nothing but the truth

00:00:49 truth thank you very much mr blades don't sit down make yourself comfortable

00:00:57 yes mr chairman thank you mr blades good morning morning can i start by saying thank you to you for coming to the inquiry and giving us evidence today uh to assist us with our investigations

00:01:08 uh to assist us with our investigations we're extremely grateful to you um my questions are intended to be short and i hope simple but if at any point you have difficulty understanding the question i can repeat it

00:01:17 it or i can put it in a different way if you feel you need a break at any time just let us know and we can take a break but we will take scheduled breaks halfway through the morning and then again halfway through the afternoon at an appropriate point

00:01:29 afternoon at an appropriate point can i also ask you please to keep your your voice up so that the transcriber who sits to your right can get down everything you say also i should just add that a nod and a shake of the head doesn't go down

00:01:41 and a shake of the head doesn't go down on the transcript you can say yes or no as appropriate that would be very helpful thank you now um you've made two statements to the inquiry uh i think the first is dated the 12th of november of 2018

00:01:53 of november of 2018 and that's cep 3064244 please can we please have that up

00:02:02 yeah and that is the one date of the 12th of november there's a signature at page 10

00:02:06 page 10 please if we can go there is that your signature

00:02:15 yes and i'm going to call that your first statement the one of november 2018 could we please also have up cep3064247

00:02:29 could we please also have up cep3064247 now this is another statement from you which responded to the inquiry's request for further evidence from you and that's dated the 16th of august 2019 can we please go to page 15 you'll find

00:02:42 can we please go to page 15 you'll find a signature there yes is that your signature yes and you also i think made a statement to the metropolitan police and that is at met3040323

00:02:57 and that is at met3040323 and that's dated the 18th of february 2019

00:03:01 2019 is that it is that that statement yes thank you uh it's not um it's not signed but it has your your signature name at the top of it that's your statement um you also

00:03:13 statement um you also made i think a statement to the metropolitan police concerning the transfer of exhibits and that's at

00:03:21 met3040322 can we please have that up

00:03:26 met 3040322

00:03:35 is that the statement transferring the exhibits

00:03:38 exhibits yes thank you very much now have you read all of these statements recently i haven't read the police ones the modern police ones but you've read the two statements you've looked into the inquiry

00:03:49 inquiry very good so that's your first statement in your second statement i'm going to call the second one the second statement and can you confirm that their contents are true yes thank you now the inquiry also received from you

00:04:01 received from you an unsolicited witness statement in october 2017. can i show you that that cep five zeros

00:04:12 8838

00:04:17 and that is dated uh as you can see at the bottom under a signature the 24th of october 2017. and is that your statement yes i'm going to call that the all 2017 statement

00:04:28 to call that the all 2017 statement just so we clear about it and under the contents of that statement true yes have you discussed with anybody the evidence that you're going to give today no i'm going to start with the first

00:04:39 no i'm going to start with the first topic which is um the history and role at cep that you uh you had it's right i think that you joined cep in 2000 isn't it correct and prior to joining cep you

00:04:50 correct and prior to joining cep you worked for about 15 years in a window manufacturing business yes and initially cep just to be clear your role was business development manager and sales representative correct and is

00:05:02 and sales representative correct and is it right that between 2004 and 2017 you were a director of cep 2013 until 2013 when the business was sold

00:05:12 sold 13. yeah and in 2000 2013 cep was sold to

00:05:17 to is it xerxes equity yeah that's correct and that meant that cep joined what was called or is called the omnis group of companies correct right and omnis i think is made up of a number of companies serving the construction industry

00:05:29 construction industry is that right yes and is it right that each one is a distinct company but they all share facilities such as human resources and accounting that's correct

00:05:37 correct and from 2013 um your job title is his right was commercial projects manager uh the commercial projects manager was uh probably 2016. right

00:05:49 uh probably 2016. right what was your job title from 2013 uh i think it was national glazing manager national glazing manager what was it in 2012 before the sale i would have been a

00:06:00 before the sale i would have been a sales director of cep architectural facades thank you now your line manager uh at least in 2000

00:06:09 2000 and from 2012 is this right was neil wilson

00:06:12 wilson he uh yes

00:06:16 he uh yes um when the business was sold in third and

00:06:19 and end of 2013 roy feuster who was the managing director became the managing director for about 12 months of the new business right um and then when he relinquished that

00:06:31 when he relinquished that it wasn't uh he wasn't to share or anything

00:06:34 anything neil wilson then became the line manager i see so new roy fooster was your line manager in 2012 and then yes and after that it was uh in 2013

00:06:44 2013 it would have been it was neil wilson yes thank you 2014 because it was business was sold in 2013. when in 2013 december oh i see at the end of the year yeah right and i think you retired in 2019

00:06:57 right and i think you retired in 2019 uh 2018

00:07:01 uh 2018 18. november 2018. um i want to examine with you cep's position in the supply chain um in general terms to start with um

00:07:13 um in general terms to start with um and first of those subtopics which i'm going to look at would be cep services um now cep is or was in the period 2013 to 16 i think a fabricator

00:07:24 period 2013 to 16 i think a fabricator of panels for use as rain screen on exterior cladding systems on buildings yes correct is it right or do i have this right that to fabricate cladding

00:07:35 fabricate cladding cep take flat panels of products delivered to it from the manufacturer and then cut and fashion them to a particular size shape and design for fitting onto a particular building

00:07:46 for fitting onto a particular building that's correct and where cep is not contracted to provide the design of the facade is it right that the customer would have to supply the design to cep that's correct

00:08:00 is it right also that every facade or element of a facade that cep supplied was effectively bespoke for an end buyer

00:08:08 end buyer or client yes uh now we understand and we'll come to this in detail later but cep works with aluminium composite panels or acm does cep work with composite panels

00:08:20 does cep work with composite panels skinned

00:08:21 skinned with other metals or did it during the period 2012 to 16. uh no it never successfully got a contract for anything other than the aluminium skins

00:08:30 skins i see so no zinc no thing no did it ever work with non-metal skinned rain screen panels such as for example marley natura no have you ever heard of marley nature yes yes

00:08:42 marley nature yes yes and what is mali natura um i think it's uh cement fibre board yes is it right the cep also works with a variety of manufacturers

00:08:53 variety of manufacturers of original products such as 3a who make a luca bond yes and in general terms is it fair to say that cep

00:09:03 that cep makes its money by providing a service within a supply chain of specif for specific projects between the manufacturer and the end client yes

00:09:14 could you just tell us in in brief terms how cep makes its profit from the fabrication of cladding panels they buy they purchase the panels from

00:09:25 they buy they purchase the panels from the

00:09:26 the supplier they manufacture the raw panel then we fabricate it and then put a profit margin to that and transport cost etc i see and um

00:09:37 i see and um you say uh i think you get profit transport cost et cetera that would include the fabrication cost the fabrication yes the fabrication the panel the yes the labor too

00:09:49 labor too yes and would it follow from that answer that in order to maximize the profit cep would aim to buy the products from the manufacturer at a low price and then sell them at a higher price building in the fabrication

00:10:00 higher price building in the fabrication costs

00:10:01 costs transport costs and the markets yes and presumably you would have a commercial interest in trying to negotiate the lowest price with the panel manufacturer yes yes is it right

00:10:14 yes yes is it right tell me that in that in 2012 14 those years you would enjoy preferential rates um in general or would you negotiate individual prices on each

00:10:26 negotiate individual prices on each order for each problem we'd negotiate individual prices for each order right i see so you weren't as it were as a favored

00:10:33 a favored a favored buyer no i see and can i then turn to the question of design services in your in your witness statements you mentioned mr mark hayward who has a

00:10:44 mentioned mr mark hayward who has a company or or firm i think called mark hayward associates mha that's correct that's right and is it right that he he's a facade or was a facade designer yes correct and

00:10:56 yes correct and i think this is in your statements but correct me cep would subcontract him in to design cladding from time to time where the client wanted a design service if cep was providing that service yes i

00:11:08 if cep was providing that service yes i see

00:11:09 see and in what circumstances would mark hayward be contracted in to perform design services if cep were selling the complete system to a contractor

00:11:21 to a contractor then and design was required by us or by cep then mark would be employed to do the design right why would a subcontractor prefer to

00:11:34 prefer to design themselves as opposed to leaving it to you to supply the full package we we our cep would uh contract with a principal contract

00:11:45 uh contract with a principal contract remain contractor um and there wouldn't be a subcontractor involved that would be a material only supply

00:11:52 supply so we will supply and design the the rain screen system to a main contractor who would in turn employ an installation team to

00:12:01 team to to fit it to the wall so there was no direct subcontractor right and where that happened would there be direct contact between cep and the installation team so that the

00:12:12 and the installation team so that the user

00:12:12 user through that would be directly put through the main contractor i see right and what would be the reason why a main contractor wouldn't come to you for the full package but would prefer to just leave it all to

00:12:25 but would prefer to just leave it all to the subcontractor and have the subcontractor buy in materials and do the design themselves sure you can just run that one again why would a main contractor prefer to go through a subcontractor for design rather than

00:12:36 subcontractor for design rather than coming to cep for the full design and supply package it would be more cost effective for them to do that because they wouldn't they wouldn't

00:12:47 because they wouldn't they wouldn't incur the subcontractors profit margin it would be more cost effective for a man

00:12:56 man yeah yes that's what i thought and cep themselves wasn't an installing contractor we didn't do any installation we didn't have that facility right so just cutting to the point on a

00:13:08 right so just cutting to the point on a job like grenfell would it have been more cost effective for ryden to have come to cep direct for the for the design as well as the supply as opposed to using harley possibly yes yes

00:13:20 possibly yes yes um in your 2017 statement the unsolicited one can we go to that it's cep 508838

00:13:34 it's cep 508838 um can i ask you to go to page 7 please and look at paragraph 7.10 and you describe

00:13:44 describe quoting there for a a full cladding system

00:13:51 and you say halfway down this is my standard offer on cladding systems i would not have to liaise with mark hayward or any other designer at this

00:14:02 hayward or any other designer at this point as this is the standard system the company will always propose at this stage of discussions and the context of this is that you were intending to quote for the um at the very start of your discussions about grenfell in

00:14:13 about grenfell in april 2 2012. [Music]

00:14:19 and you say at the beginning of that paragraph he was intending to quote for the full cladding system i i just want to ask you what you mean by my standard offer do you mean there that at an early stage in design cep would generally

00:14:31 in design cep would generally as a matter of course offer a complete package system with insulation cavity barriers claddings fixings and design yes if that's largely what the project was going to be required so that would

00:14:43 was going to be required so that would be a a budget figure that we would take from historic works uh just to give the client or the architect in this case you know a feel for what where we would

00:14:56 you know a feel for what where we would where cep would be with sort of prices really right and would there be a design cost built into the price that you can charge the client

00:15:06 client and that would be that would be the cost of the design which would be outsourced we had

00:15:17 just tell me a little bit about that standard package was that originally designed by mark hayward associates or yes it would have been yes i see do you know when it was originally designed um i believe it was

00:15:31 um i believe it was um possibly the late 80s early 90s right and was it kept up to date with current standard as far as i'm aware um it was when i think more we always

00:15:42 it was when i think more we always relied on mark here would to keep us up to date with stuff right and would mark haywood develop the specification and substitute products where necessary

00:15:53 products where necessary not naturally no that would be down to the client the architect or whoever's specifying the materials i see

00:16:03 i see and so if design changes like product substitutions were made would you expect that a designer like mark hayward associate well it would be mark haywood associates to have considered those substitutions

00:16:14 to have considered those substitutions not necessarily not that they would come from the client we mark would only work with you know what we

00:16:21 what we were if we were you know the supplier of material what the client had changed material to yes

00:16:30 there was i think a time when cep produced its own facade build up in about 2016 is that is that right

00:16:38 how would you mean our own design builder

00:16:42 builder did was there a new system available in 2016

00:16:48 not that i can recall right

00:16:54 does a does the name petrarch or petrac panel

00:16:58 panel mean anything to you yes um

00:17:03 is it right that in 2016 the petrak panel

00:17:06 panel uh became the new cep off-the-shelf product within the petra was um another division of the old cep company

00:17:18 company it was nothing to do with the scent helens operation it was manufactured down in hastings right

00:17:27 right and that would have got under the head in origin of cep claddings okay we may come back to that in general terms did cep perform a design service itself at any stage uh or simply fabrication just peel the

00:17:40 uh or simply fabrication just peel the fabric here should it fabrication am i right that when you supplied an off-the-shelf design for example the mark hayward design um

00:17:53 for example the mark hayward design um or the petra design perhaps am i right that cep

00:17:57 that cep sells all of the component parts itself so cladding insulation cavity barriers fixing elements yes yes we did originally that that did change

00:18:07 change right away now for the grenfeld project we understand that the component parts of the facade were were sourced separately insulation was sold separately from from

00:18:19 insulation was sold separately from from cavity barriers from rain screen panels and at the time of uh the supply to grenfell tower was it common

00:18:27 common for cep to supply only some component parts to the project rather than to supply the fully designed package it had become that way later on cep's history

00:18:40 that way later on cep's history just the way the market had changed right

00:18:43 right when when did that market start to change can you tell us i would say guess sort of the mid 2000s right so is this right the cep

00:18:55 right so is this right the cep gradually during the mid-2000s began to be called on to supply only component parts correct and that would be to subcontractors of main contractors would it yes i see and with them with the

00:19:06 yes i see and with them with the majority of those parts um rain screen and windows yes what about insulation um they could stop they could buy their own insulation yes they would buy their own

00:19:18 insulation yes they would buy their own insulation they could buy their agency would you be would you ever be asked to supply in insulation possibly yes i see but what was the most common element of a rain screen cladding system

00:19:30 element of a rain screen cladding system that you would be asked to supply as a single component after the mid-2000s do you think the panel the panel possibly the rails right at the rails or the panel

00:19:44 and where you are where you were asked to supply the panel and possibly the rails

00:19:49 rails would cp simply have sourced and fabricated them in accordance with the design supplied by the client or would you investigate how the

00:20:00 or would you investigate how the panel or rails would fit into the overall cladding system

00:20:05 sorry can you just well let me ask it a different way where you were asked to supply component parts would cep simply source them fabricate them and deliver them uh without asking any questions about how they were to fit into the overall

00:20:17 how they were to fit into the overall rainscreen system or did you investigate how they would fit in to the overall rain screen system no we would leave that the the final decision to the subcontractor we would just fabricate

00:20:30 subcontractor we would just fabricate them

00:20:31 them or supply them to their design requirements i see

00:20:38 and at the time of the supply to grenfell tower and we're looking at 2015 now effectively can you tell us even if in broad terms what proportion of cep's business

00:20:51 what proportion of cep's business was providing component parts to order as we've discussed as opposed to providing a a fully designed off-the-shelf package 2015.

00:21:04 probably 6 16 50 50 50 the full system and 50 components right

00:21:16 and 50 components right i'm now going to turn to the um the string of contracts just by way of an overview on the grenfell tower project and it's right i think that cep contracted with harley in around december september

00:21:30 with harley in around december september september 2014 to supply fabricated window frames and glazing that's correct yeah and then in february 2015

00:21:38 2015 to supply fabricated cladding panels and fixings

00:21:42 fixings uh i think it was just the panels only in the end i'm not yeah i'm not sure about the fixing or i think it was just a panel or something let's ignore the fixing but the certainly the fabricated final panels

00:21:53 certainly the fabricated final panels yes

00:21:55 and we know i think that cep was not ultimately contracted to supply the complete facade just those components now i want to look at the role that ce plea cep

00:22:05 plea cep played in the supply chain um first of all arconic who i think were called alcoa

00:22:10 alcoa at that stage um is it right that cep had worked with alcoa later arconic for a number of years prior to the grenfell tower refurbishment yes and we'll come to look at that in

00:22:24 yes and we'll come to look at that in in due course in some more detail but we understand that cep entered into a contract with arconic for the supply of the reyna bond pe55 rain screen

00:22:36 reyna bond pe55 rain screen panels the acm panels in in march 2015 for the grenfell tower project correct yes now looking at the history of the relationships with the parties in the supply chain can we

00:22:48 the supply chain can we go to your first statement please and i want to look at studio e to begin with first statement cep3064244 and i'd like to go to page four

00:22:59 to go to page four and look at the bottom of the page paragraph 16 and the bit i want to look at goes over the page you say you say there i first became aware of the refurbishment in around march 2012 when discussions with

00:23:11 around march 2012 when discussions with studio e began you say i do not recall how the initial contact arose but i i assumed the studio we approached cep given that i had no knowledge of the planned refurbishment at this time

00:23:22 planned refurbishment at this time just pausing there how do you ever come across

00:23:26 across studio e before the grenfell tower refurbishment no

00:23:31 do you know how studio e came to learn of you

00:23:35 of you no i no ryden is it right that you'd worked with ryden before on i think the challenge state product

00:23:43 product project yes that's 2006 wasn't it yes um were there any other projects on which you had worked previously with ryden before the grenfell tower project

00:23:55 grenfell tower project we were we worked with them on the chalcott estate through harley as a subcontractor yes any other project no no and and

00:24:07 no and and harley uh let me just ask you about harley

00:24:11 harley are you saying in your police statement that you worked with harley i think on 10 projects before the grenfell tower project

00:24:17 project is that right i would believe so yeah yes

00:24:20 yes um just for the reference it's your police statement at page four um the main one now i'll give you some names and just check them off would that include waylon's house yes

00:24:31 would that include waylon's house yes olympic way wembley i believe so yes yes you've mentioned child cuts clements court again i believe so i wasn't

00:24:40 wasn't involved in that personally okay

00:24:44 can we go then to the offline uh of this document cep503010

00:24:58 now this is a list of uh projects done by cep prepared by cep after the fire with input from deborah french of arconic

00:25:12 and uh what you'll see there is a an excel spreadsheet um do you remember this document have you seen this document before

00:25:23 seen this document before yes i believe i have um and if we go down to row 38 uh thank you

00:25:33 third yes it's divided up into parts and yeah this part is under projects december 13 to june 17. and cell 38 or row 38 is wayland's house yeah and you can see that

00:25:44 yeah and you can see that looking across the page um

00:25:49 you go to columns h and i you could see harley curtain wall in column d uh and you can see an h rayna bond p e and i face rivets and face rivets is

00:26:02 e and i face rivets and face rivets is is

00:26:03 is is riveted or face fixed i think isn't it correct as opposed to cassettes correct yes um and we can see the cladding panel as i say was brainerborn pe phase fixed so

00:26:14 pe phase fixed so so the supply to uh waylon's house was was it was it pe cord i believe so if it's

00:26:22 it's here yes and we could see others up in the list saying fr but yeah and that stands for is that fire retardant if you look higher up

00:26:33 fire retardant if you look higher up see for example that fall kirk was um fundamax fr fire retardant and looking at some other projects um if you go

00:26:44 you go to um row

00:26:48 to um row 71 what yes row 71 you've got olympic whey wembley again harley curtain wall panels only a luco bond under column h

00:26:59 a luco bond under column h p e face rivets you see that yes uh and chalcott's uh going up to pay to row 57 uh is uh reyna bond p e face rivets

00:27:13 uh is uh reyna bond p e face rivets and again clements caught at 58 just below that hounslow clements court uh panels reinaborn pe face rivets um do you know whether cep

00:27:26 um do you know whether cep ever supplied cladding to harley with any core other than pe not that i'm aware of right is it your recollection that most of the time when you supplied cladding panels

00:27:37 time when you supplied cladding panels to harley you were supplying face fixed panels

00:27:42 um [Music]

00:27:47 yes yes

00:27:52 and in fact looking at this spreadsheet am i right that grenfell tower was the only project with harley where cep supplied cassette panels

00:28:05 yes yes but it looks at this looking at this list of projects and one can go up a little bit scroll up a little bit towards the 2013-17 section of it

00:28:18 towards the 2013-17 section of it that uh

00:28:22 you regularly supplied this is right both pe and fr panels for high-rise buildings

00:28:33 the the the fundamax product isn't an acm right folker project well let's look at

00:28:44 folker project well let's look at row eight let's just try one try one on you and then we can move forward uh row eight um is badger street birmingham building

00:28:55 is badger street birmingham building height 30 meters so it's above 18 meters it's a residential and rainer bond fr went on to there you see that yes

00:29:08 so that's an example of where you did supply fr to a high rise and there's another one at row 34 i think

00:29:16 think um

00:29:20 no that's pe but that's uh that that's a pe cassette also at high rise you see that which is a commercial yes um

00:29:31 um would i be right though in saying just in general terms that you would supply fr and pe it would appear from that um those two projects i wasn't involved in

00:29:43 projects i wasn't involved in right just in general terms what would prompt a contractor to choose pe as opposed to fr core acm panels where where they were both available

00:29:56 the um

00:30:00 i would say that the fr became more prominent

00:30:03 prominent after the grenfell tower right more prominent um more prominent yes i can understand that but before the grenfell when you say after the grenfell tower do you mean

00:30:15 say after the grenfell tower do you mean the fire or the project the fire right is that i understand before the fire and and particularly i'm interested in the period 2012 to 2016

00:30:27 the period 2012 to 2016 certainly 15 i'm interested in what would prompt a contractor to choose pe as a core for an acm panel as opposed to an fr

00:30:37 to an fr core i i i'm not sure i'm not sure why the the contractor would have a reason for you probably does a very reason i wouldn't be aware of what his reason was

00:30:50 be aware of what his reason was right but you deal with um and suppliers or end buyers do you know from your experience of your buyers market why it

00:31:02 experience of your buyers market why it would be

00:31:03 would be that a buyer would choose pe if fr was available

00:31:10 no not really no what would mark hayward associates uh put into the full-blown cladding system design where that was ordered by an end buyer would it be pe or would it be fr um

00:31:23 would it be pe or would it be fr um i i i i'd have to ask him what he would do in that situation i can't answer for him right

00:31:39 we'll come back to to that issue later on

00:31:45 is it is it right that uh um

00:31:51 uh um zinc panels for example made by kme and i'm thinking specifically of the proteus

00:31:59 proteus hr zinc panel would be supplied ready fabricated by kme and wouldn't need to come to cep i i guess i've never dealt with and we never dealt with them at all and i personally was aware of the

00:32:11 and i personally was aware of the company but i wasn't aware of the products at yes does it follow that anybody coming to cep would necessarily be looking for a supply of acm panels can you can you repeat that one again

00:32:22 can you can you repeat that one again yes if anyone was coming to p to cep and asking for rain screen panels they would necessarily be asking for acm not necessarily no what else would they

00:32:34 not necessarily no what else would they be asking

00:32:35 be asking we had uh the fundamental product that's there and we had one called steny which was a

00:32:41 was a reconstituted stone right um stenit reconstituted stone is that the steny of looking at this yes standing nature in color reconstituted stone is that a particulate

00:32:53 particulate yes like cementitious particulate um no it's it's it's more of a storm with a

00:32:59 with a fiberglass resin backing right and thunder max what is thunder max

00:33:07 max thunder max is a high pressure laminate oh i see

00:33:10 oh i see hpl hbl right and what core did the stenny nature and stenit product have

00:33:18 have it didn't have a core in the same sense as an acm

00:33:23 as an acm it was a fiberglass and resin matting and then um stone was mixed on the on the surface of the external surface of it

00:33:34 external surface of it right and why would buyers customers clients

00:33:38 clients select stenit a a reconstituted stone as opposed to for example acm the stania was sold

00:33:45 was sold primarily into scotland into the scottish market and it suited the scottish

00:33:51 scottish building landscape building the landscape the exterior of the building it just suited what they're using i see so aesthetically rather steady from a regulatory point of view yeah it's we did i think

00:34:03 yeah it's we did i think four blocks in bright and long before i joined cep and everything else for instance it went to scotland and what about thunder max what's the what is the skin or the

00:34:15 what's the what is the skin or the external surface of fundamentals the hype the

00:34:18 hype the the hard pressure limit that's um that's layers of paper or thin card and resin right that's compressed together to make a high pressure laminate uh okay and is there a core there isn't

00:34:31 uh okay and is there a core there isn't a coil

00:34:31 a coil in the same way no and why would again why would buyers prefer funder max as opposed for example to raino bond acm whether pe or ifr funder max

00:34:42 acm whether pe or ifr funder max the high pressure laminates were around before

00:34:45 before largely before the acms came to be they were a flat surface very resilient board um very good weatherboard etc that was used on the external

00:34:56 on the external buildings right i think you said before that

00:35:00 that um you you when it when it came to metal skinned

00:35:04 skinned panels you would only work with aluminium is that is that right with acms not with true uh monolithic aluminium we didn't have a

00:35:13 have a the plant to fabricate through you know three mil aluminium i i see okay and what about zinc never worked with zinc right so i was

00:35:24 never worked with zinc right so i was going to ask you some questions about zinc composite materials zcm have you heard of zc i haven't but you're i think you're telling a cp would not work or did not work with zac we hadn't worked with it

00:35:35 we hadn't worked with it right can i then turn to your relationship with arconic now you say in your first witness statement at paragraph 12 that cep had a long-standing commercial relationship with arconic alcoa

00:35:46 relationship with arconic alcoa denarconic among other panel manufacturers is that right yes

00:35:51 right yes and i think cep had been working with arconic

00:35:54 arconic as a supplier to cep since about 2006 is that right correct yes and am i am i right in thinking and i i get this from your statement but the first time you worked with arconic

00:36:06 the first time you worked with arconic and specifically rayna bond acm was the childcare estate project in london in 2006 correct did you ever visit the iconic factory in murksheim in france

00:36:18 murksheim in france um we are told by mr vela in his witness statement paragraph 105 and i'll just put the reference into the transcript it's met3053190 page 30.

00:36:32 it's met3053190 page 30. the cep visited for a technical presentation there in the february of 2006.

00:36:39 do you know anything about that no can we take it that it wasn't you i didn't go enough you didn't go do you know whether it took place at all i don't know

00:36:50 i don't know you don't know um did our did cep have uh an account with iconic yes did cep have an account with 3a

00:37:02 with 3a uh eventually yes eventually when um i'm not sure i would maybe 2014 15. i'm not sure and

00:37:15 15. i'm not sure and did having an account with our colleague make it much easier to make all the place orders uh it it wasn't any easier to place

00:37:26 uh it it wasn't any easier to place orders

00:37:27 orders right what caused cep to open an account with 3a in 2014 or 2015 do you think prior to that our uh three years sold through distributors

00:37:40 uh three years sold through distributors um and then i i would guess that they decided to sell directly to fabricators like ourselves yes i see

00:37:52 would you describe cep's commercial relationship with arconic which you had i think from 2006 as a strong one a good one oh a good one yes

00:38:03 a good one oh a good one yes is it fair to say that you would prefer to work with arconic if possible over over other manufacturers no no no now deborah french says in her statement

00:38:14 statement uh and for the reference this is met3053 at page two there's no need to turn it up paragraph five she says in her second statement that she joined arconic in 2007

00:38:27 arconic in 2007 and that's her recollection of her joining arconic have you or had you been dealing with deborah french from that time 2007 do you remember

00:38:38 you remember i don't recall no how would you describe your relationship with deborah french the professional business working relationship a good one good good commercial

00:38:49 a good one good good commercial relationship

00:38:52 how would you describe whatever you like everything like the other relationship with others yeah yes now before 2012 is it right you worked with deborah

00:39:03 is it right you worked with deborah french quite often on projects and it quite often is a bit of a vague question but reasonably frequently um yes and did she visit cep's workshop from

00:39:15 and did she visit cep's workshop from time to time yes did she give cep information and brochures about rayna bond products probably yes did you ever meet her away from your workshop from time to time

00:39:26 workshop from time to time only in meetings such as you know if we had to go to a meeting together right a meeting with with architects right

00:39:37 a meeting with with architects right okay architects on projects on projects yes

00:39:40 yes so you would would would you habitually go with ever french to meet architects on projects no not habitually no no only when only when needed be who would decide whether she should come

00:39:52 who would decide whether she should come um would the architect say bring deborah french yes you could do yes if they if they wanted product knowledge of of um

00:40:00 um arconic then i would take rene bond of their referencing with me right can we go to excuse me can we go to cep3051312 please

00:40:13 cep3051312 please this is an email chain in april 2014

00:40:20 and i want to look at the email from you to her

00:40:25 to her um at the top of that page this is in response

00:40:29 response to hers to you of the 25th of april 2014. now there's there's a quite a long history yes so your involvement in the project which we're going to come to later but i just want to

00:40:39 to look at this email run your response to her uh is debs you say i will always believe you capitalized but not all sales reps as i'm from that background exclamation

00:40:51 i'm from that background exclamation marks whereas alcoa employ honest highly trained professionals enjoy your holiday

00:40:57 i'll just show you that as an example but is it right that that exemplifies the

00:41:01 the sort of relationship you had with her informal and and one of of trust yes did that kind of relationship enable cep to get favorable deals on acm

00:41:13 enable cep to get favorable deals on acm panels

00:41:13 panels i wouldn't say so no no there were other iconic sales reps in the uk i think at the time have you ever heard of robert campbell no

00:41:23 no robert campbell worked on the rayno lux product he represented our iconic for the sale of rayno lux did you know that

00:41:32 know that i may have heard that but i've never met the gentleman i've i don't know of him right and rayna lux is aluminium cladding with no core it's not an acm did you did cep ever work with reynold

00:41:44 did you did cep ever work with reynold lux no

00:41:45 lux no i see did cep or did cep ever work with solid metal panels at all i see only core so

00:41:56 you didn't work with robert campbell did you work with anybody else supplying rainer bond acm uh when debbie french left arconic

00:42:07 uh when debbie french left arconic there was a gentleman called vince meakins took her place i see and can you give a date to that um no no not really right

00:42:26 now you you've told us that if a designer

00:42:29 designer this is a slightly separate question from the relationships question but but you told us that if a designer chose for example solid aluminium or solid zinc then that wouldn't be cep's no job you wouldn't be

00:42:43 cep's no job you wouldn't be you wouldn't be manufacturing those right can i then turn to your own personal

00:42:50 personal experience and knowledge um and i want to start with your your experience of clatting and windows i think before you see ep as you told us you worked in wind lead window manufacturer yes correct um and

00:43:03 window manufacturer yes correct um and are therefore very familiar with window products

00:43:05 products technology suppliers etc is it fair to say that before you came to cep you had a great deal more experience in and expertise in windows correct than cladding correct yes

00:43:17 correct than cladding correct yes have you ever had any training in cladding technology no and does it follow therefore that you've never had any training in the fire performance of cladding products no now we looked at the question of core

00:43:31 no now we looked at the question of core before we know that acm comes in a variety of different calls or at least two

00:43:36 two pe and fr i want to focus on pe can we go please to your 2017 statement at page 10 2017 statement is cep

00:43:48 at page 10 2017 statement is cep 508838 page 10 please and i'd like to look at paragraph 7.36 with you

00:43:58 with you three quarters of the way down the page under the heading alteration from zinc to aluminium cladding and you say at 736 the available you say that the the um

00:44:12 the available option after steny and zinc had been discounted given price was an issue was a standard aluminium composite material with a paint finish iconic alcoa at the time produced a rainy bond acn panel commonly referred

00:44:24 rainy bond acn panel commonly referred to as raynabond acm this product would have a pe core

00:44:31 um and you refer to it as i say as a standard and would have a pe core and you you say in paragraph 737 just below it that pe stands for polyethylene

00:44:44 below it that pe stands for polyethylene and describes the material placed between two aluminium panels to make up a rain screen panel the panel forms the exterior of the cladding system and what you've said out there did you know what you've set out of paragraph

00:44:55 know what you've set out of paragraph 736 and 737 that at the time of the grenfell tower project

00:45:02 so can you ask the question please well let me try it a different way um [Music]

00:45:09 [Music] was the supply of a standard acm with a pe core something that you uh had experience of at the time of the grenfell tower project so

00:45:20 time of the grenfell tower project so from 2012 onwards yes yes what was your understanding at that time in other words within that period of what polyethylene was

00:45:36 with regard to what what sort of material was not other than it was the core of the yes of the panel well what is polyethylene well it's a plastic it's a

00:45:47 polyethylene well it's a plastic it's a plastic and you knew it was a plastic then did you

00:45:51 not particularly i didn't take that bit on board it was just a pe core right and never looked in in great depth did you know that polyethylene was combustible

00:46:03 combustible no i imagine mr blaze you'd seen many of these panels in

00:46:10 in in the flesh so to speak yes so you you would have recognized the fact that it was there was something between the two yes correct skins of aluminium and it possibly looked a bit plastic isn't it

00:46:22 possibly looked a bit plastic isn't it correct yes did it ever occur to you consciously this is plastic not that i'm aware of no right

00:46:34 um can we please look at miss french's second witness statement and i referred to that earlier it's met3053162

00:46:46 at page seven please and i'd like to look with you mr blades paragraph 28.

00:46:58 and uh

00:47:01 she says about halfway down that block of text

00:47:07 of text she says of course i appreciate that pe was

00:47:10 was plastic do you see that just just below halfway

00:47:14 halfway yeah yes of course i appreciate that pe was plastic and was and is flammable that would have been obvious to anyone the pe product was regulated and accredited by external accreditation

00:47:25 accredited by external accreditation bodies for example the bba and when she says that pe was classic and wasn't as flammable that would have been obvious to anyone was the flammability of pe obvious to

00:47:37 was the flammability of pe obvious to you at the time you uh worked on the grenfell project no

00:47:43 so did you never discuss the flammability of pe with miss french no what about with the designer mark hayward

00:47:50 hayward mark a wood wasn't involved in the grenfell tell us i wouldn't discuss it with him i had no reason to no but he would have been in doing designs on other projects using pe called acm or yeah and never did it with him either

00:48:04 or yeah and never did it with him either right

00:48:07 right before the grenfell tower fire so june 2017

00:48:11 2017 if a uk customer ordered acm did you understand them to be ordering a panel with a p e corps yes so you you understood that the that

00:48:23 so you you understood that the that would be

00:48:24 would be the default or standard order in the uk could understand the render bomb in that case i see

00:48:33 can we go to your second witness statement and i want to look at fr core as a comparator this is your second statement uh page five please and i'd like to look at paragraph 24

00:48:52 now you say there

00:48:56 it's cep3064247 page five so this is your second statement

00:49:02 statement page five paragraph 24. you say that underneath the heading rayna bond with an fr call you say as far as i'm aware this product is class naught

00:49:16 is class naught yes

00:49:19 and then you go on to say at the in the last sentence it was not until after the refurbishment that cep became aware that arconic supplied an fr product namely rayno bond fr

00:49:32 fr product namely rayno bond fr when you say recently when do you think you did learn about fr chord acm panels

00:49:40 i don't recall it wasn't a product that rena bond or arcanic pushed

00:49:48 you say pushed or promoted right but they did supply it

00:49:55 possibly yes you say possibly it sounds like we navigate we you know we prior to the those days we hadn't

00:50:02 hadn't i hadn't uh used the fr product no but were you aware that rayna bonds that iconic supplied raynor bond acm with an fr core

00:50:16 no not right we may come back to that shortly um but so let me just go back to my my question said that i have your evidence on it do you remember when it was after

00:50:27 on it do you remember when it was after the

00:50:28 the grenfell tower fire that you did become aware that um that arconic supplied an fr called acm panel

00:50:36 panel no i don't recall that right

00:50:42 um can we go to cep3049832

00:50:49 now this is an email exchange in june 2013

00:50:54 2013 between you and richard geeta if that's the right way of pronouncing it at 3a

00:51:02 it at 3a about another project so this is not grenfell

00:51:05 grenfell and you were asked um by him we can scroll down the uh email chain we don't need to well let's look at the second let's look at the whole exchange it starts at page three but the context here is that

00:51:17 three but the context here is that you're asking about the pricing of rayner bond as a compared with the pricing of three eighth product the luca bond that was what you're interested in and if we start at page three um we can see that richard gita comes to

00:51:30 um we can see that richard gita comes to you and says this is the 10th of june 2013. hi jeff when you have a moment i wondered if i could inquire if our direct rates are a more attractive proposition and also have closed the gap with reyno

00:51:41 and also have closed the gap with reyno bond

00:51:42 bond uh many thanks best than thank goodness and then if you go to page two he's you go back to him and

00:51:53 he's you go back to him and you say looking at the latest quotes you were slightly higher about 130 per square meter you you say you have quotes on based on hpl and then um if

00:52:04 hpl and then um if you look a little bit above that on the page 14th of june he comes back to you hi jeff thanks for the feedback may i ask if the rainer bond offer is for pvdf fire rated core um just to start with

00:52:17 fire rated core um just to start with what is what did you understand by pvdf i think that's the finish uh the paint finish

00:52:23 finish right and then he says fire rated core and then if we go up to the first page at the bottom of that page you reply to him on the 17th of june as we see

00:52:34 him on the 17th of june as we see just scroll up to the bottom of page one you say morning richard ref reyno bond i don't think so but didn't request that spec

00:52:46 spec so is it right looking at that that in june 2013 you knew that arconic did make a radar bond product with a fire rated core but just hadn't asked for it on that occasion

00:52:57 for it on that occasion is that how we should read that possibly yes i see

00:53:04 staying on that page looking up the page to the top you can see the 3a composite reply on the 17th of june richard guitar says hi jeff that clarifies the price difference a luca bond has an

00:53:16 difference a luca bond has an fr core and pbdf paint system as standard

00:53:20 standard alcoa can offer this but they will charge considerably more than one pound 30

00:53:25 30 per square meter alcoa won't change their core until they are forced due to changes in the fire regulations else rayna bond will become too expensive 3a comp 3a composites are heavily

00:53:37 3a comp 3a composites are heavily marketing rfr core discussing the requirement for fire retardant materials with architects especially on residential buildings now when you received that you couldn't have been in any doubt could you that arconic did make an fr

00:53:48 could you that arconic did make an fr product correct right so you did discover before the fire that arconic did make an fr acm product looking at that yes i see

00:54:00 acm product looking at that yes i see so you are you prepared to correct the evidence you gave earlier on yes i will thank you i don't remember that email we've just looked at now we call it receiving that email okay and is it right that

00:54:11 is it right that at least looking at this that in fact it was a significantly more expensive product than a pe core product yes

00:54:22 yes you aware from that that fr would have a better fire performance than acm uh with the pe core looking at this yes yes and

00:54:34 looking at this yes yes and it would follow looking at this the aluko bond supplied sorry 3a supplied its own fr product namely a leukobond correct yeah and a loop that alcoa

00:54:45 correct yeah and a loop that alcoa iconic weren't selling the fr version of an acm panel because it would make their acm product uncompetitive looking at this yes yes right

00:55:02 and again looking at this and i see if see if this is prompted a recollection if our ffr core was available to an architect or a subcontractor for example looking

00:55:13 or a subcontractor for example looking at rain screen acn why would they opt to buy a pe core at all

00:55:19 all where it was to be used over 18 meters they probably wouldn't they probably wouldn't

00:55:27 do you know why it was even offered over 18 meters where fr was available sorry can you yes do you can you think of any reason why

00:55:38 of any reason why uh any any architect or clouding subcontractor would would buy a pe called acm panel where fr was available where where the building project was over 18 meters

00:55:51 project was over 18 meters no

00:55:54 um can i ask you to look at deborah french's second witness statement

00:56:01 six met3053162 and i'd like to go to go to page eight please uh which

00:56:10 is now there on the screen if you look please at paragraph 32 six lines also down from

00:56:21 the start of the paragraph she um says and this is the context of the different markets and in germany

00:56:34 of the different markets and in germany uh she says it was more usual for customers to order fr and then she says i do not know the reason for this but i assume that it related to the respective regulatory regimes i would also add that

00:56:46 regulatory regimes i would also add that fabricators in the uk did not really like working with fr because it is more difficult and costly to fabricate than pe for example it tends to wear down the cutting tools much more quickly than pe

00:56:58 cutting tools much more quickly than pe this was a general comment made by fabricators i worked with including for example sotek cgl and if we turn the page and argonaut but i cannot recall a specific instance of

00:57:09 i cannot recall a specific instance of when a fabricator told me this is debra french right that fr core at acm

00:57:16 acm is more difficult or more costly to fabricate for the reasons she gives i couldn't say because i didn't get involved in the production side at cep so right had you ever heard it said

00:57:29 so right had you ever heard it said that fr was more unattractive for fabricators in the position of cep where they were asked to fabricate an fr core because it was more costly to

00:57:40 an fr core because it was more costly to fabricate because it wore the tools down more quickly sorry can you repeat the first part yeah had you ever heard industry discussion that fr

00:57:51 that fr was was more expensive for fabricators to fabricate because for example it wore down the tools no no can you comment on what she says there about that not really no

00:58:06 about that not really no no

00:58:14 it looks looking at the list that was put together on the spreadsheet we looked at earlier that cep in general did supply more pe core than fr core at least during the years 2013-17

00:58:26 during the years 2013-17 correct that'd be right correct yeah now we also know that arconic developed

00:58:39 now we also know that arconic developed its own

00:58:40 its own a2 standard core in about 2015 to 16 which achieved a euro class a2 fire classification did you know that no did any customers

00:58:53 did you know that no did any customers to your knowledge ever ask cep specifically for a2 cord products no

00:59:02 can i then turn to the question of fixing methods and i want to ask you about the fabricated product in your experience as at the period 2012

00:59:13 in your experience as at the period 2012 to 15 did customers tend to prefer cassette fix cladding or riveted cladding

00:59:24 i i don't believe there was a particular choice

00:59:28 choice the architect or the client would have had a preference himself to either a face fix where you potentially could see rivets to a a cassette fix where you can't see the fixings it was purely

00:59:40 can't see the fixings it was purely aesthetic in my belief right in general terms though did you detect a preference for one or the other not really no right

00:59:56 in in in terms of output from your plant would you deliver more cassettes than rivet or more rivet than cassette i

01:00:08 than rivet or more rivet than cassette i know it's a very general question but can you give us a feel for that not really no right now i want to turn to fire performance and the question of class naught now if you go to your second witness statement

01:00:20 you go to your second witness statement page five please

01:00:23 second witness statement uh i want to look at paragraph 22 and this is under the heading understanding of one fire performance and classification and two pricing and

01:00:34 and classification and two pricing and reasons

01:00:35 reasons for variations in pricing of types of rayna bond acm before the fire at grenfell tower on the 14th june 2017 and in that paragraph you

01:00:46 and in that paragraph you say three lines down this being said or perhaps i should start at the beginning you say as regards to the refurbishment as outlined in my witness statement of

01:00:57 as outlined in my witness statement of 12 november 2018 cep was never asked or instructed to carry out an assessment of the regulatory and legislative compliance of the exterior of the building

01:01:06 building this being said as outlined above a paragraph 19 cep understood that the rayner bond panels were classified as class naught as under the building regulations and it was therefore our understanding that

01:01:18 was therefore our understanding that they could form part of a safe and compliant structure that was designed by other parties class naught is what you've written in that sentence

01:01:29 that sentence your cep understood your personal understanding at the time that was my personal understanding right how did you come to that understanding

01:01:44 um i i don't recall just through listening and learning from the people we'd worked with

01:01:55 we'd worked with was there any purpose or point of cep knowing the fire classification

01:02:09 i'm not sure what what what you mean by the question please let me try it again was it relevant to cep to know that the raynor bond panels were

01:02:21 that the raynor bond panels were as you understood it classif classified as class naught yes i will believe so what was the point of that what was the purpose did it comply with the building regulations why did it matter to you

01:02:32 regulations why did it matter to you cep that it complied with the building regulations it was it was just a compliant other than compliant with building regulations um

01:02:44 that was about it right well my question was really why was it why did it matter to you why was it wrong it was a product that did comply with building regulations as

01:02:55 did comply with building regulations as opposed to a product that didn't comply with building regulations you know it met a standard of some degree right so did it matter to cep that it it

01:03:07 so did it matter to cep that it it supplied a product which complied with the building regulations i would say so yes

01:03:11 yes is that because you didn't want to supply a product that didn't comply with the building regulations yes yes and well just just tell me mr blade

01:03:20 blade as i understand it you get an order from a

01:03:23 a a contractor um please make up the following

01:03:28 following cassettes or panels whatever correct of the following material is that right correct and why does it as mr millet was putting you why does it matter to you whether that material is compliant with

01:03:41 whether that material is compliant with the building regulations or not it would probably be more concern if we it was a project that we were designing oh yes that's as opposed to

01:03:53 oh yes that's as opposed to somebody saying can you fabricate this panel in some cases we may not know what the building is or if we get a panel schedule through for

01:04:04 if we get a panel schedule through for instance that's just a series of panels with a particular size and shape to them so if we're providing our own work with our own design then we would ensure that

01:04:15 our own design then we would ensure that um you know it met the building regulations i understand that certainly thank you yes thank you now if we look at page five of your witness statement i'd like to look at paragraph 23 we're still on page five in fact but

01:04:27 23 we're still on page five in fact but paragraph 23 you say under the heading acm render bond acm with a pe call you say i understand that this product is a is class naught performance

01:04:38 product is a is class naught performance uh

01:04:41 uh and at paragraph 24 under the heading raynor bond with an fr chord you distinguish pe from fr when you say you understand

01:04:53 pe from fr when you say you understand that this product that's the pe core in paragraph 24 is class naught where did that understanding come from

01:05:08 understanding come from millet i'm sorry to uh interrupt you but i think

01:05:11 i think is he is mr blade's not speaking in paragraph 24 of the fr core yes i've gone back to paragraph 23. oh

01:05:18 oh right i'm not sure that was good well that's my fault i apologize um looking at paragraph 23 then just focusing on that and you say i understand that this product is class naught performance

01:05:29 naught performance and my question is where did that understanding come from i would have heard that in conversation right did you ever see any documents or

01:05:41 right did you ever see any documents or it would or it would be referencing the bba uh the bba all right well we'll come to that later on in your evidence

01:05:52 and what about the fr product under paragraph 24 you say as far as i'm aware this product is class naught for our performance again where did that understanding come from

01:06:03 from again i would have heard that in conversation and possibly from some documentation

01:06:13 now can we look at

01:06:21 um the bottom of that page um you can see that it says under a heading rhino bond with course of different colors for example translucent or black

01:06:35 and if you turn over to page at the bottom of the page you say as far as i'm aware these are class naught and i'm not aware of any price differences

01:06:46 aware of any price differences uh what do you mean by by that what do you mean

01:06:50 you mean i'm not aware of any price differences i wasn't aware that the color of the core had a price difference oh i see right were you aware of any

01:07:01 oh i see right were you aware of any difference in price between pe and fr

01:07:06 i am now but at the time i wasn't aware uh other than going back to say the luca bond 3a there was no

01:07:17 luca bond 3a there was no and if you go to page six of this statement

01:07:20 statement you can see a question or sub question in italics there

01:07:25 reyna bond that is face fixed or heading rainer bonded his face fixed riveted to buildings you there say as far as i'm aware this is class north and i'm not aware of any price differences again are you saying that there's no

01:07:37 again are you saying that there's no price difference between uh between face fixed and cassette

01:07:45 no i think what is being said there is there is no price difference between the renault product whether it's phase fixed or formed into a cassette

01:07:59 i see price difference to the material i see to say price difference for you kept buying from renault bond yes yes i see

01:08:08 see but there would be a price difference for the end buyer correct yeah

01:08:16 can we uh just stick with this you're saying here that as far as you're aware phase six renault bond was class naught but you don't mention here of what you know about the classification

01:08:27 classification um of the rayner bond cassette system the fire classification of the raynabon cassette system what did you understand the fire classification of the cassette uh fix rhino bond to be as at 2013.

01:08:41 uh fix rhino bond to be as at 2013. i would understand it to be a class or as it's the same material were you aware of any classification differences between face fixed and cassette fixed raynaud no

01:08:54 um you mentioned the bba certificate a moment ago in your evidence i want to start on that topic just generally we'll come to it in more detail later on but i just want to ask you about it generally where bba certificates uh asked for

01:09:07 where bba certificates uh asked for by building professionals so far as you're aware when considering what cladding materials to use on the building

01:09:15 building occasionally yes yeah and was it your experience that the the detailed information contained in a bba certificate would routinely be considered by those building professionals architects or

01:09:26 professionals architects or sub-cladding subcontractors i will believe so yes right did you ever get any questions yourself asked to you about the details contained in in bba certificates numerical

01:09:39 certificates numerical do you know what status the the bba certificate for for example um renault bond and pe called

01:09:46 called acm had in the industry what status it had how important was the bba certificate i i i don't know i'm not aware of that

01:10:00 right you asked to provide the bba certificates yourself or or in your experience was that something that architects or buyers would ask directly

01:10:11 architects or buyers would ask directly of the manufacturer sometimes if they may ask for it through ourselves

01:10:16 ourselves right or they make they may take it direct from from whoever they require that information from right

01:10:28 and would you supply the bba certificate to your customer your end buyer as part of the contract package

01:10:36 package if we were asked to yes right

01:10:44 did the fact that the panel had a bba certificate

01:10:49 help you market the products which would be the subject particularly now right

01:10:58 now right can we go to your second witness statement at page 14 and i want to ask you some questions about what you knew about fire safety test results now

01:11:09 fire safety test results now at the top of page 14 you can see that you're you're asked a question in the context of your first statement where it says you state that deborah french provided harley and you a

01:11:21 deborah french provided harley and you a copy of the bba certificate zero eight four five one zero for rayna bond cladding prior to this this is the question were you aware of the bba certification of rayna bond and in particular its fire

01:11:33 rayna bond and in particular its fire performance rating and your answer is uh yes uh i was aware of the certification and by default its fire rating as class naught

01:11:44 uh what did you mean there by by default

01:11:52 i i just the fact that i was aware that the product was class or

01:11:59 um well it doesn't quite answer the question you use the words by default it's fire rating as class naught can you just explain what you mean in that sentence

01:12:10 that sentence looking at the question that you were asked

01:12:17 other than i would have seen the class or rating within the bba certificate i see so do you mean that because you knew of the certification

01:12:29 because you knew of the certification ergo i'm sorry to use that word um you knew it was not it was class north or thought it was class naught yes that was you took the certificate of face value yes yes now paragraph 67

01:12:45 you say under the question what did you understand class not to mean and what do you think its significance was you say i understood that class naught meant that the product was of limited combustible nature

01:12:57 combustible nature linked to surface spread of flame i understood that it met the required standards of the building regulations what did you mean there by limited combustible nature linked to the surface spread of flame

01:13:11 it didn't instantly ignite it had a limited amount of combustibility right what was the source of your understanding that class not meant a limited combustible nature

01:13:27 could you re-ask the question yes you say i understood that class naught meant that the product was of limited combustible nature how did you come to that understanding

01:13:39 how did you come to that understanding how did you learn that i i don't recall it's maybe something that was probably said within the office at the time at some point or became aware of it through

01:13:50 or became aware of it through general general office conversations or industry conversations right and

01:13:59 right and you say that you understood that it met the required standards of the building regulations how did you come to that understanding do you think

01:14:06 again i i don't recall particularly how i came but right did you have a working knowledge of the building regulations no

01:14:17 can we go to cep five i'm sorry six zeroes one four eight cep 60148 please this is uh cep's quotation from february 2013

01:14:30 2013 to lead bitter for the grenfell tower project

01:14:33 project and it's in fact signed by you um i don't think we need to see

01:14:40 that but if you go to the top of the page you can see it's sent to mohit kotecha

01:14:45 kotecha at lead bitter date of the 4th of february 2013 and you are quoting there in the second paragraph for rain screen over clouding panels and column casings

01:14:57 panels and column casings are to be manufactured utilizing four millimeter rainer bonds zinc pattern of paint finished acm you see that yes and then you say towards the bottom of the page

01:15:09 towards the bottom of the page rayner bond acm panels achieve the following

01:15:12 following class naught bs 476 part 6 and class 1 bs 476 part 7 reynabond acm achieves bba accreditation where did you get that information from

01:15:24 where did you get that information from do you think i i don't recall it's not something that you would have had in your head is it maybe it was i was aware that brenner bond had a baby

01:15:35 that brenner bond had a baby certification and i was aware that it met class or yes um but you go on to say class naught bs 476

01:15:45 476 part six and class one bs476 part seven that's quite technical and my question is is that something you knew as it were off by heart off the top of your head or did you have to look at a document to put those

01:15:56 to look at a document to put those technical details in there i would have i i i would have been advised that somewhere by someone i couldn't answer that right it's just something that um i was

01:16:08 right it's just something that um i was aware of

01:16:08 aware of how i came back i can't recall and we just put it in the in the doc in that letter right

01:16:19 do you think you might have

01:16:22 i see did you realize that the bba certificate for rayno bond doesn't actually say that the pe called acm the standard sample passed those particular tests

01:16:34 particular tests only the fr panel had achieved class naught in testing to bs 4 7 6 6 and 7. no i didn't right did you know what bs 476 part 6 and bs

01:16:46 did you know what bs 476 part 6 and bs 476 part 7 results meant when you set them out

01:16:49 them out in your quote here

01:16:53 i had a a brief understanding of what the two parts were

01:17:01 right

01:17:05 and what was that i think i think the part six

01:17:09 part six was um the time it took for a panel to ignite

01:17:15 ignite uh and part seven was how far it spread in this given set time right and is that something you uh knew from looking at documents or something you just gathered

01:17:26 something you just gathered as part of your experience i would have been told it or gathered it through my experience yet right did you do it did you ever do any training on the building regulations and fast testing and classification

01:17:37 and fast testing and classification right

01:17:42 did you know that in fact it's not correct that that the acm pe panels had achieved a class naught four seven six part six and and part seven uh test right

01:17:54 and part seven uh test right did customers ever ask for details or reports of bs 476 fire performance testing whether part 6 or part 7 or both not that i'm aware of what about european classifications again not that

01:18:06 european classifications again not that i'm aware

01:18:07 i'm aware about certification to br 135 criteria that i'm aware as far as involved not that i recall did you ever read br 135 which deals with insulation no did you have any knowledge of bs 8414

01:18:21 no did you have any knowledge of bs 8414 tests

01:18:22 tests no if a customer had asked you about whether a particular product whether it was insulation or rain screen panels uh had passed fire tests and classification

01:18:34 tests and classification uh would you have answered yourself or would you have referred to somebody else i would have referred it back to somebody else who would have you referred it to do you think it could be the material supplier or or maybe uh market would associates

01:18:50 and would mark hey would associates be as it were an in-house source of that kind of information that you could just he could he could probably answer the question he may have documentation that would answer the question that's it and he was a resource for you

01:19:02 that's it and he was a resource for you you would use regularly or always available yes it was available if we needed to ask him questions certainly if the project was an in-house design

01:19:10 design project yes i see mr chairman i've got about four or five more questions on this topic before changing topics maybe why did you finish that would be convenient thank you can we go back then to our discussion about the cep design system

01:19:22 cep design system in light of what we've just been talking about

01:19:26 in in design terms can i go please to

01:19:34 cep3057377 this is an email from roy fuster in may 2016

01:19:42 2016 subject cladding fire test reports and uh

01:19:50 and uh the attachments you can see there

01:19:54 and roy feuster says finally and i think this isn't just help me is this an internal email looks as if it is yes yeah finally

01:20:05 looks as if it is yes yeah finally exclamation marks please find attached br135 testing certification um and this is a test or certification which comprises

01:20:18 a test or certification which comprises a br 135 report and a bs 8414 report about a cep system with a as it turns out a petra panel were you aware yourself of the

01:20:30 panel were you aware yourself of the fire

01:20:30 fire safety testing done on that system no no

01:20:37 did you personally appreciate at the time of the supply of the rain screen panels

01:20:42 panels on the grenfell tower project of how cladding systems could comply with the applicable provisions of the building regulations and approve

01:20:53 and approve document b no

01:20:57 now looking at this email would you accept that there were at least some people

01:21:01 people within cep so neil wilson your line manager and roy feuster your your x line manager i think that that did appreciate the need for cladding systems

01:21:10 systems which were sold by cep to be fire tested yes yes was that new as at the date of this email say 2016 or was that always the case before that

01:21:23 or was that always the case before that i think this would be new what was the reason for that being new was there a new concern or a new

01:21:35 concern or a new i require sure i'm not i'm not aware of that so i can't answer that did cep obtain fire test data such as this

01:21:42 this for all systems supplied to it by end users

01:21:45 users not that i'm aware of right

01:21:49 and so that wouldn't have included supply of acm panels for the grenfell tower project presumably that i'm aware of no is there a reason why there is that distinction you would provide a fire test you'd get a fire test or certification for

01:22:01 test or certification for the system you see in 2016 but not for the supply of the acm panels to grenfell not that i'm aware of right do you know any reason why that is i don't know okay

01:22:13 don't know okay mr chairman that may be a convenient moment right thank you very much well mr blades we're going to have a short break now um i'm going to ask you to go with the usher and come back in let's say 20 to 12. please

01:22:27 let's say 20 to 12. please while you're out of the room on this and any other later occasions please don't talk to anyone about your evidence or anything to do with it okay thank you all right thank you would you like to give the usher please thank you

01:22:50 20 to 12.

01:42:17 thank you would you like to ask mr blades to come back in please

01:42:33 all right mr blades you ready to carry on yes good thank you very much yes mr millet mr chairman thank you mr blades i'd like to ask you some questions now about the chalcott's estate project that's a project isn't it where

01:42:45 project that's a project isn't it where cep

01:42:46 cep supplied rainer bond panels in london county town and first of all the contractors on the project were right and weren't they correct

01:42:57 right and weren't they correct uh and halling harley was the cladding subcontractor correct and arconic supplied the raynor bond cladding correct uh and i think you told us earlier this was the first time cep had worked with arconic then alcohol um

01:43:11 arconic then alcohol um and harley did the design for the cladding at chalkers didn't it correct were you aware that chalcott had a four millimeter acm panel face fixed and had a rock wool duo slab insulation

01:43:23 and had a rock wool duo slab insulation behind it within the system i was yes yeah and the acm that was used on that project was a rayna bond acm with a pe core

01:43:35 was a rayna bond acm with a pe core correct

01:43:36 correct do you recall who specified the rain screen material for that project i don't um

01:43:47 there was a problem with the initial acn that was on the buildings yes at albany tell bond and then i don't know who then came back and and

01:43:58 i don't know who then came back and and specified

01:43:59 specified uh brenda bond right do you remember whether it was the architect or whether it was harley who specified it right i don't know

01:44:13 do you remember whether it was you who recommended reynabon it wasn't me it wasn't you and now do you remember that in january 2012

01:44:24 2012 there was a fire in one of the chalcott's tower blocks namely taplo house

01:44:29 house does that ring a bell with you yes it does

01:44:32 does and there was a report um done by harley of that fire an incident report do you remember that have you seen it i haven't seen it no you haven't

01:44:43 you haven't uh i see

01:44:48 uh i see uh can i just show it to you um we can go to the

01:44:52 go to the offline reference to it which is cep five zeros three two two two please this is the email chain

01:45:05 this is the email chain with the abseil report attached to it and i'll just show you the bottom of the first page

01:45:17 first page uh

01:45:21 you can see um that you were copied into an email

01:45:26 an email below that which uh forwarded the report so we start with the email from roy feuster to you at the bottom of page one

01:45:36 and the subject is uh fw forward taplow house fire damage do you see that [Music]

01:45:45 [Music] we're looking at page one second email on that page yes yes and your um that that comes to uh

01:45:57 to uh it comes from roy feuster to neil wilson and steve roberts yes and then immediately above that yeah just below the line steve roberts

01:46:08 yeah just below the line steve roberts sends that to roy feuster and copies you correct you see that yes as well as neil wilson right now let's just then look below

01:46:15 below at the email on page starts on page two in substance the very start of it's at the bottom of page one the substance of is on page two hi roy please see attached a report

01:46:26 two hi roy please see attached a report with regard to the fire damage at taplow house camden we have now been told that they wanted to get on with the repair stroke replacement work and it goes on to detail that the damage is 17 stories

01:46:37 is 17 stories up in the air we proposed replacing all the damaged panels and then in the next paragraph we would need you to provide the rayna bond rails and windows now just looking at that email chain would you accept that historically

01:46:50 would you accept that historically you were copied into an email which forwarded

01:46:54 forwarded the report attached by um by ray bailey to roy feuster in june 2012.

01:47:02 2012. yes thank you did you read that report i may have done at the time right let's look at page two um i'll give you the reference it's cep

01:47:14 um i'll give you the reference it's cep five zero

01:47:14 five zero three two two three and let's go to page two

01:47:26 and you can see

01:47:31 if we go to page 2 that it says that the uh in the second paragraph the damage was clearly evident internally with

01:47:42 was clearly evident internally with extensive damage to the fabric of the building structure which included damage to the concrete frame which exposed rebar to the ceiling you see that yes and then

01:47:53 you see that yes and then if you um

01:47:57 go on it says the very bottom of the page

01:48:00 page however the fire was contained from spreading to over floors by the extensive fire breaks located at and you have to turn the page the head and sill of each window smoke

01:48:11 the head and sill of each window smoke damage caused further damage to the external cladding and cavity now do you remember reading uh that at the time when you got this report in june 2012.

01:48:23 2012. i don't recall reading it but um right i probably will have done if my name's it's been forwarded to me but i don't recall it yes and after that fire did you think

01:48:34 you think about the extent to which the cladding had contributed to the damage caused by the fire

01:48:41 no i don't recall did you or anybody else at cep consider any lessons to be learned

01:48:47 learned from the taplow house fire not that i'm aware of did the fact that this fire had taken place and the rainer bond had performed in the way it

01:48:58 rainer bond had performed in the way it did not prompt you to consider its safety

01:49:00 safety from a fire perspective it didn't me personally no did it anybody else at cep i can't i i can't say i don't know is there no discussion within cep about

01:49:11 is there no discussion within cep about the safety of the the rayner bond product from that i recall

01:49:19 right can we look at the statement of mr vela of arconic please this is one nine met3053190

01:49:30 and i'd like you to go to page 29 of that please and look at paragraph 103

01:49:40 and he says at the bottom of that page there as far as i'm aware my only contact with ryden prior to the grenfell tower fire was in relation to a separate project where rayner bond product had been fitted

01:49:50 fitted on a project at camden in london the childcare's estate and then he says this i was asked by vince meakins to attend a site visit with himself and two people from ryden allen white and steve blake on 4th of may 2017

01:50:04 and steve blake on 4th of may 2017 in relation to a delamination issue allegedly affecting some panels fitted to those blocks during that meeting we walked around the perimeter of all the tower blocks at the childcards estate and the technical delamination matter was

01:50:15 technical delamination matter was discussed

01:50:16 discussed a sample of the material from one of the towers was taken by one of the writing representatives and provided to me for further review and then he says this during the course of that site visit i

01:50:27 during the course of that site visit i expressed to the two ryden representatives surprise to see a number of buildings of such height with acm pe cladding material rather than an fr product the ryden representatives

01:50:39 product the ryden representatives commented that the relevant uk regulations allow the use of acm pe products in such scenarios i did not make any further inquiries relating to uk regulations following

01:50:50 relating to uk regulations following this comment by ryden now

01:50:56 first of uh first of all were you aware of this visit made by mr vela to chalkers in may 2017 i don't recall being aware of it no

01:51:07 i don't recall being aware of it no right

01:51:08 right did you ever meet mr vela at any stage no

01:51:24 can we then turn to cep's role in the specification of rayner bond acm from 2012 and i'd like to start if i may in march 2012

01:51:36 like to start if i may in march 2012 with the initial meetings uh uh in relation to grenfell tower can we go to cep6043 i'm sorry seven zeroes four three

01:51:51 um this is an email of the 29th of march if we go to page two it's an email run that ends on the fourth of april in this document that starts

01:52:01 starts on the 29th of march and at the very bottom of page two we can see that bruce zones sends you an email on that day grenfell

01:52:12 sends you an email on that day grenfell tower upgrade meeting fourth of april to 11am and that's the subject

01:52:16 subject and he says hi jeff please see our address and details below i appreciate you coming in we are currently working at risk for kensington until funding is secured and then he asks you in the next uh um

01:52:29 and then he asks you in the next uh um the next well i'll show you the intention is to procure the project as an add-on

01:52:34 an add-on to the neighboring project the kensington academy and leisure project please could you bring pictures or drawings of the enfield homes project i think it will be a useful reference when discussing it with our client i think i could see the enfield towers from the roof of grenfell see attached

01:52:47 from the roof of grenfell see attached um do you know whether there were any communications between you and studio e that preceded this one no do you know who affected the introduction

01:52:58 introduction i believe that studio e contacted the office

01:53:03 office cp's office do you know how cep came by c sorry how studio e came by cep i don't know now you became aware at this point that studio e was the

01:53:15 at this point that studio e was the architect for the grenfell tower project

01:53:19 is it right that from the very outset you therefore knew that grenfell tower was a high-rise building correct in other words over 18 meters right can i ask you to go to

01:53:29 max402709 please page one uh

01:53:40 page one uh this is an email from

01:53:47 bruce sohn's studio e on the 29th of march 2012. so the same day as the email i've just shown you to you and it's to mark anderson

01:53:59 to you and it's to mark anderson at the tmo copied to people at max fordham

01:54:04 fordham and curtin's consulting and others subject grenfell tower upgrade you see that

01:54:10 that yes and it looks from this that he had set up a meeting with you uh to discuss budget and options if you look at the third paragraph down he says in the in that paragraph in the

01:54:22 he says in the in that paragraph in the second sentence i have set up a meeting here with cep and provides a web address next week wednesday to discuss options and budgets for the overcladding

01:54:34 did you understand that the purpose of mr sohn's

01:54:37 mr sohn's seeking a meeting with cep was to discuss

01:54:41 discuss options and budget for overcladding

01:54:45 yes it was to yeah i wasn't aware he was looking for budgets but possibly yes yes do you remember whether a meeting did take place that in that following week in other words

01:54:57 in that following week in other words the week after the week of weekend in which the 29th of march sat no i couldn't get i couldn't make it on the fourth if that was the week after inclement weather

01:55:07 weather and i arranged to go down the week after i think it was the 11th now let's look at page

01:55:20 we can go to back we can go back to cep 7043.

01:55:30 we can see how the email run with studio e pans out the top of that page um we have marcus keefer of studio emailed to you on the fourth of april the original date for the meeting

01:55:42 the original date for the meeting and and you're you're right because in the second email down from that you email him that day to apologize for the english weather and the meetings postponed to the 11th and then in the

01:55:53 and then in the in marcus keith's email to you he says in the second paragraph since we have

01:56:00 have a further meeting with the client on the morning 9th of april 2012 we would appreciate your initial thoughts regarding the appropriate cladding systems and the rates associated with them

01:56:10 them what did you understand mr kiefer to mean by appropriate cladding systems there

01:56:16 there what system we could offer um you know what cep had to offer in in relation to um grenfell tower right or to a tower block

01:56:27 block at that stage was there any discussion or thinking either between you and studio e or internally at cpcep as to whether it would be a bespoke full-blown tailor-made system or just

01:56:39 full-blown tailor-made system or just supply of individual components we would have thought it could have hoped it would have been a full complete system

01:56:46 system right and is that because you would make more money on it no it's because what we do we supply or then we supply the complete full system right um can we then go to your second

01:56:57 right um can we then go to your second statement

01:56:57 statement uh at page eight your second witness statement cep3064247 please and i'd like to go to page eight paragraph 40 as we see there you say

01:57:08 paragraph 40 as we see there you say responded um you say i responded to bruce sainz at studio e on the fifth of april uh and halfway down that paragraph you say i did not consider

01:57:19 say i did not consider that this was a request for advice but was merely providing information at this stage

01:57:27 um but the question i have is didn't you understand mr kiefer to be asking for advice about what cladding would be appropriate for grenfell tower he asked me for my

01:57:40 for grenfell tower he asked me for my initial or our initial thoughts and um whether that was advice or inquiring what we offered i i just took as a general enquiry to what we could offer

01:57:51 what we could offer yeah you say i didn't consider that this was a request for advice my question is why not well maybe i did or

01:58:00 or just the way i read it as it was just uh you know what can we offer whether that was classes advice or our thoughts or um you know i didn't read too much into

01:58:11 um you know i didn't read too much into other until i met the gentleman right did you tell mr keefer that you couldn't personally or corporately advise on an appropriate cladding system i didn't tell him that no

01:58:22 tell him that no did you tell him that cep would have to engage a designer such as mark hayward associates in order to provide the advice he don't recall if i did at that stage okay now we can see if we go to cep70

01:58:36 that in his response of the 4th of april mr kiefer attached some floor plans as as well as

01:58:47 the um south elevation and some photos you see that in the first paragraph of his ears

01:58:54 now in your i'm sorry to jump around if you go back to paragraph 41 of your statement second statement page nine cep30642.247

01:59:05 second statement page nine cep30642.247 page nine you say it paragraph 41 uh and it's the previous page i'm afraid

01:59:21 we go back to page eight you say there at the bottom of the page i would not have given any advice because we were not aware of a specification now in fact marcus keefer's email did

01:59:33 now in fact marcus keefer's email did attach as i've shown you floor plans the south elevation and photos of the tower so you were given specifications weren't you

01:59:41 you i don't think there was a specification for materials or products i think it was an outline of what the building was rather than requesting specification of materials

01:59:51 materials well what do you mean when you say that you weren't aware of a specification a specification to me would be um where they specified particular materials what

02:00:02 materials what the cladding panels for instance windows for instance uh what they want to achieve i don't recall that what marcus sent through had a sort of specification

02:00:14 had a sort of specification as such right but given that you were sent indicative existing floor plans and the south elevation and some photographs was that not enough detail for you to be able to provide at least some

02:00:26 least some information or advice on an appropriate cladding system as mr kiefer had asked for

02:00:30 for yes

02:00:34 so why didn't you go back to him with some advice or information about an appropriate cladding system we i believe we sent him some um

02:00:45 we i believe we sent him some um indicative details down but no rates were given right

02:00:53 did you consider that what you had from him was not enough

02:00:57 sorry did you think that what you'd had received from mr kiefer was not enough for you to be able to advise him on an appropriate clutting system i believe that the stuff the information

02:01:09 i believe that the stuff the information we sent down was so he could attend a meeting prior to me meeting them to get more information of the project right i wonder whether we're getting a bit caught up on the word advice which

02:01:21 bit caught up on the word advice which may have different connotations of different people yes my understanding of the position is that uh mr blaises that cep was asked to give an indication or make a proposal

02:01:33 indication or make a proposal is that what you understood that's why i would say yes thank you yeah but i also understand that you would not propose something you didn't think was suitable correct so you were um

02:01:46 so you were um providing information about what you could do

02:01:51 could do on the basis that you thought it was a suitable thing to offer yes correct right is that are you trying to get up more than that mr minute well i want to know whether or not what

02:02:02 not what what mr keefer had given you was sufficient for you to be able to do what he'd asked you uh i

02:02:13 probably probably not other than giving indicative details of what he was looking at i can't recall every detail that we got through i do record there was a picture of the elevation

02:02:24 elevation but i'm not sure exactly what he sent through at this moment in time we don't see that you went back to marcus keefe and told him that you needed

02:02:31 needed more information or a specific spec in order to provide the thoughts he'd asked you for

02:02:36 you for well i believe i was going to a meeting a week later i see so you do it at that stage yes

02:02:44 stage yes let's go to cep70

02:02:55 this is an email you wrote on the 5th of april to bruce sown so the day after seeing marcus keefer's email and you sent him 15 pdfs which are drawings showing a cladding system

02:03:07 system correct yes so just just pausing there you did actually send some uh design information or detailed technical information on cladding to mr sones in response to the request

02:03:19 sones in response to the request yeah in response to uh marcus request yes then let's go to one of those attached drawings it's cepc please

02:03:35 and this is a drawing by mha mark howard associates in from january 2008 you can just see that at the bottom right hand corner

02:03:46 that at the bottom right hand corner of a typical windowsill detail at stratford house which was a a project where the client seems to have been mha's client was cep architectural facades

02:03:56 facades now stratford house was a 66 meter 23 floor residential high rise wasn't it i don't know the height of it but it was a tall building yes it's all building over 18 meters at any rate i would think

02:04:08 over 18 meters at any rate i would think so and this is a sill detail in the bottom corner tags we can see the product can you see that um and the rain screen is four millimeter thick ppc

02:04:20 millimeter thick ppc aluminium composite panel correct and does ppc mean polyester powder coated it does yes an acm we know aluminium composite we know and it shows a rivet doesn't it

02:04:31 a rivet doesn't it yes yes and what it's worth while we're on it rock wool duo slab insulation correct before you send those drawings to mr sainz did you

02:04:42 sainz did you pass the the query that you'd received from marcus kiefer to mha to ask him what suitable cladding systems

02:04:50 systems or what drawings he should provide or you should provide i don't i don't recall whether i asked more for them or whether they were available within cep to send

02:05:02 they were available within cep to send down right if they weren't available within the sort of cp file documents i would have asked mark to forward them to me right do you accept that by sending these drawings of past

02:05:13 these drawings of past projects such as stretford house to studio e

02:05:16 studio e you were giving studio e the impression that you were willing to give advice on suitable cladding systems for grenfell tower in the future yes probably yes and

02:05:27 yes probably yes and as part of that to be advising that acm cladding could safely be used on grenfell tower

02:05:38 can you re just rephrase that yes and as part of

02:05:41 part of that exercise providing them of indications of suitable appropriate cladding systems that acm as the rain screen could could be used safely on grenfell

02:05:52 could could be used safely on grenfell tower

02:05:53 tower i believe so yes yes now on the 11th of april

02:05:57 april you referred to that date earlier you i think did go for a meeting with bruce sones

02:06:01 sones and marcus kiefer of studio e correct was that on site at grenfell terra it was

02:06:07 was did you discuss rain screen cladding

02:06:12 i don't recall but we probably would do because that was the purpose of the visit

02:06:20 to to discuss the cep products i see you you say the purpose of the visit was to discuss what they was looking for for grenfell

02:06:31 what they was looking for for grenfell tower

02:06:32 tower appropriate cladding systems yes i see did you understand that to be an entire system

02:06:37 system or just the rain screen element the entire system right so um can you tell us what products you discussed at that meeting i don't recall what products in particular right did you discuss acm

02:06:50 particular right did you discuss acm i don't recall right can we move on in time then to october 2012 and start there with your second witness statement cep3064247 page six and i want to show you

02:07:02 page six and i want to show you paragraph 32 please

02:07:08 you can see that at 32 [Music]

02:07:11 [Music] under the heading use of rhino bond 55 on grenfell tower

02:07:17 you say in the second sentence i introduced deborah french of arconic to studio e

02:07:23 studio e as being the representative of arconic who could demonstrate their products however i had no involvement in the discussions um so is it right that just looking at that that

02:07:33 that that arconic came to be involved in the grenfell tower project because cep introduced them to it correct now i think you had a meeting with studio e on the 16th of october

02:07:45 with studio e on the 16th of october 2012.

02:07:47 2012. correct and we can see an email cep 503 961 please

02:07:57 this is an email of the 9th of october 2012.

02:08:05 from you to bruce on that day subject grenfell tower hi bruce just to confirm our earlier telephone conversation ref the above that myself and debbie french of raynabon will meet at your office next

02:08:17 raynabon will meet at your office next tuesday 16th october 11 30 to discuss zinc rain screen

02:08:23 screen now um first was that was that meeting to your knowledge the first meeting that deborah french had with studio e to my knowledge yes yes did bruce says

02:08:34 to my knowledge yes yes did bruce says ask

02:08:35 ask for that meeting in other words a meeting with deborah french or did you and deborah french suggest it to bruce sones i would have um suggested it to bruce

02:08:46 i would have um suggested it to bruce stones to introduce renault bond or their zinc product to to them because cep

02:08:53 cep didn't have a zinc product cp didn't we've never we'd never worked with the zinc i see we're going to come back to that in a second because i'm interested in the zinc but before i

02:09:05 i'm interested in the zinc but before i get there can i ask you why did you only bring deborah french of arconic to that meeting and not only representative of any other manufacturer of of of panels because i i i was aware

02:09:17 of of panels because i i i was aware through either historic conversations or seeing a sample that renabond had a zinc appearance finish to a panel or a zinc panel yes does it finish to a panel did

02:09:29 panel yes does it finish to a panel did no other manufacturers have a zinc finish i don't recall them doing but i don't know what about vm's inc i don't know them i didn't know them at the time did you think of looking around the

02:09:41 did you think of looking around the manufacturers market to see if anybody else did a zinc product no right so was your thought process they want a zinc panel i'll think of debbie french i'll take her to the meeting

02:09:51 meeting no i they were looking for zinc panel and i was aware that reynabond had a zinc

02:09:57 zinc finished panel right

02:10:02 did you take a note of this meeting do you remember um i believe i did yes do you still have those notes

02:10:10 i don't think i do no have you have you looked for them i know there's one in the documents right

02:10:17 right um in terms of the cladding materials under discussion at the time of this meeting

02:10:21 meeting and obviously we can see from this email that studio we was considering zinc as the as the material for the rain screen did you discuss zinc as a cladding option zinc itself as

02:10:34 zinc as a cladding option zinc itself as opposed to a zinc finish i didn't personally know right was there a discussion about any other finish other than zinc itself in the meeting yes in the meeting i

02:10:47 in the meeting yes in the meeting i believe so yes what was what did you discuss i think rena bond or debbie french discussed options where they you can offer finish to replicating right

02:11:01 i see so those were different options from

02:11:04 from a zinc finish when you say zinc finish was discussed was that the zinc composite material yes i became aware of of how they

02:11:16 produced that panel they had a skin of zinc a very thin sheet of thing that becomes bonded to

02:11:24 to a core in there with an aluminium phased core right now i i think you told us earlier this morning that cep didn't as it were do zinc correct uh

02:11:37 cep didn't as it were do zinc correct uh and didn't do zcm given that the purpose of the meeting as we can see from this email

02:11:41 email was to discuss zinc range screen what did you think that ce what did you think cep's role would be in in in that is it in the no i i guess i would have had a conversation

02:11:52 i guess i would have had a conversation with bruce to explain that there was a product that we could offer that had a zinc finish to it i i didn't know particularly till i got there how they was viewing zinc in their in their

02:12:03 they was viewing zinc in their in their opinion oh i see so do i understand it this way that you thought you were going to the meeting to discuss

02:12:10 discuss a zinc finish yes in other words a non-zinc material got up to look like zinc or the building they required to have an appearance to

02:12:21 they required to have an appearance to zinc to the external face right i see and the fact that as you said that renabon had a product that had a

02:12:29 had a zinc appearance finish the object of the meeting was to see if that was suitable

02:12:37 did it become clear to you at that meeting that uh bruce sainz wanted actual zinc in other words the metal is yes right and how did that what did you think about that i i i got the impression that he was

02:12:49 i i i got the impression that he was open to

02:12:50 open to um options did could arconic supply actual zinc not that i'm aware of right

02:13:01 so how was the me given that our conic didn't

02:13:04 didn't play as you know didn't supply actual zinc um

02:13:07 zinc um other than perhaps a zinc composite um which you wouldn't cut anyway uh given that bruce zones was after actual zinc

02:13:19 actual zinc the real thing how was that meeting left um i don't recall particularly how it was left other than i think they may have requested

02:13:30 have requested some samples um of of the sink um right have a feeling that they just mentioned vm zinc

02:13:41 vm zinc yeah i think i think debbie french knew the people at vm's inc and she was contacting them right you know whether that was going down that particular road and we would have been out of the

02:13:52 have been out of the out of the project i can't recall right why would debbie french be promoting perhaps that's not too strong a word

02:14:02 a word a material made by someone other than archonic

02:14:05 archonic i believe they use vmz to provide the same

02:14:10 same skin that went on there right i see so that's a

02:14:14 that's a that's the the sheep that goes on the outer face the outer face and the interface

02:14:18 interface of zcm product but nonetheless if that had been selected you would have formed no part of the supply chain because you didn't cut zinc well we could have provided that zinc

02:14:30 well we could have provided that zinc panel because we we may not need to cut the zinc face i see if it was a face fix panel we would just drill and and fix it to the the rail river to the

02:14:41 and fix it to the the rail river to the rail system but that would have been a first for cep it would have been yes yes was it your impression at the meeting that miss french promoted the acm product when i say the acm product i mean the acm pe

02:14:53 the acm product i mean the acm pe product

02:14:54 product yes right over zinc

02:15:01 in other words in preference to zinc it was the i think that no no i think he was promoting both the the zinc finish and a traditional acm

02:15:10 acm right and when you say the zinc finish do you mean the zinc skin of actual zinc rather than the finish got it to look like i think it was down to the client or the architect of how far that was going to be taken i see

02:15:22 how far that was going to be taken i see so can we say was it your impression to summarize it that debbie french promoted the acm and the zcm um manufactured by um iconic correct i got i've got it

02:15:33 um iconic correct i got i've got it right can we then go to uh cep3048712 please this is an email from you to deborah french on the 16th of november 2012.

02:15:45 french on the 16th of november 2012. and you say to her subject grenfell tower hi debs just spoke with adrian jess at studio e who we met and they're still going along the rinsing route but still early days and

02:15:56 rinsing route but still early days and no firm costs have been provided regarding rain screen excavation marks did you mean that studio e was opting or looking to opt for rinsing at this stage in other words a cladding that was

02:16:07 stage in other words a cladding that was not manufactured by arconic yes they they i think they had spoken to a a a business ryan thing who i'm not particularly aware of but there was a

02:16:19 aware of but there was a i believe there was a zinc another zinc panel or

02:16:23 panel or sample that they exhibited the meeting on

02:16:26 on um the day i was down there in october yes

02:16:31 yes and when you say no firm costs have been provided regarding rain screen did that indicate that it was still possible that raino bonds i'm sorry

02:16:40 i'm sorry iconics zcm or acm might still be specified with the chance i would agree yes

02:16:48 yes did you suggest at any stage to studio e or for that matter ryden or harley at a later stage that arconic products would be cheaper than reinzinc

02:16:58 no in this email were you trying to encourage debbie french to continue to push for a sale of their their acm reyna bond product

02:17:13 i always yes we would probably um you know if reynabond got in the job we would have um an opportunity yes i mean clearly if

02:17:25 um an opportunity yes i mean clearly if reinzig was selected uh then then neither you nor she would be would be correct of the project yeah and therefore it was a benefit certainly yours had certainly yes i can't i can't speak for debbie french or iconic on that matter

02:17:37 debbie french or iconic on that matter but debbie french doesn't didn't supply record

02:17:40 record yes

02:17:43 yes just thinking briefly about the differences between zcm as provided or made by iconic and acm is zcm more expensive than acm i don't

02:17:55 more expensive than acm i don't i don't know right and we never priced the zcm so i i don't know what the cost was no okay did you ever discuss the price of the potential price of zca with debra french at this stage not

02:18:07 with debra french at this stage not larry cole right

02:18:12 said you never told deborah french that zcm would be too expensive for the grenfell tower project i didn't know no um can we then move to january 2013 uh and the quotation that you supplied

02:18:25 uh and the quotation that you supplied to mohit katecha at lead bitter we looked at this earlier on uh and i think you remember

02:18:38 and i think you remember at least from what i showed you earlier that you did supply a quotation to them in january 2013. um and that i think it was followed up on the fourth of february as we've seen in the formal quotation let's just see how that builds up if you

02:18:50 let's just see how that builds up if you go first please to cep three zeros four eight eight eight six

02:18:57 this is mr kotech's email to you of the 24th of january 2013. and if you look at the first paragraph he says

02:19:05 he says jeff nice to meet you today at the baseline offices to review the grenfell tower project with gareth and myself as discussed please find attached all necessary details for cep architectural to provide a design sorry producer

02:19:17 to provide a design sorry producer design manufacturer and supply price along with installation costs from your approved installer high-rise solutions

02:19:25 and then in the fourth paragraph down he says as mentioned to aid our report next week an initial budget figure would be very handy early next week with a

02:19:36 be very handy early next week with a further more detailed quote to follow um you can see there that the subject matter that of his request is

02:19:47 subject matter that of his request is the design manufacturer and supply you see that in the first

02:19:50 the first paragraph was that a request for a full-blown cep system say supplying design services as well as all components of the facade and the windows i believe so yes right now with that

02:20:03 i believe so yes right now with that emails we can see from the attachment mr kotecha supplied a specification that is at cep304887 if we can look at that please

02:20:22 um there it is do you remember seeing this

02:20:27 yes yes uh that that's that's the first page of it i'd like to go to page six please

02:20:33 please and look with you at the middle column on page six if we could just blow that up a little bit you can see there that there is a heading external envelope

02:20:46 under the bigger heading existing residential flat level 1 to 20. you see that yes and under external envelope

02:20:59 yes and under external envelope we can see a variety of things and the third entry down is h92

02:21:07 rain screen cladding existing columns over cladding and then a bullet point vm zed composite zinc panels you see that i do yes and below that there's another

02:21:18 i do yes and below that there's another h92 entry

02:21:19 h92 entry just two below that uh h92 rain screen cladding external wall 12 millimeters hpl cladding trespa or similar and subframe system surface fix cappings to match

02:21:31 system surface fix cappings to match panel color now did you understand the vmz composite zinc panels reference in the first of those h92 references to be a reference to zinc panels with a core

02:21:45 i probably would have done at the time yes

02:21:48 yes and that would be an fr call would it i don't know i i think it would be if if deborah french is correct that would be an fr call um

02:21:59 that would be an fr call um did you understand the reference to trespa in the second h-92 reference there to be um to a high-pressure laminate or hpl composite yes now you i think respond to that

02:22:12 yes now you i think respond to that quotation

02:22:13 quotation by email on the 31st of january 2013 and let's look at that it's cep

02:22:20 60138 and i'd like to look at the first page of that second email down email from you 31st january to hamahit katcha

02:22:32 katcha subject grenfell tower external envelope inquiry morning mode gareth please see below costings ref the above rain screen overclouding rainer bond zinc pattern the paint finish which allows for under window areas columns

02:22:43 allows for under window areas columns and crown

02:22:44 and crown then you give a figure for 629 or thousand pounds installation of rain screen 183 500 pounds

02:22:51 pounds then you give a quote for windows and curtain wall and then some exclusions and if we just turn the page to see how this finishes just for completeness

02:23:02 uh i i'll provide a fully typed quotation letter monday to firm up the above trust the above meets with your approval

02:23:09 approval please ring me if you have any questions um

02:23:14 now you're specifying there reyna bond zinc pattern of paint finish if we just go back to the first page focus on those words you'll see rayna bond zinc pattern of

02:23:25 you'll see rayna bond zinc pattern of paint finish was that for rayna bond acm with a zinc pattern a paint finish i believe so yeah right

02:23:34 now skip forward to the formal quote that you you promised and indeed sent a few days later this is at cep60148 i think we saw this

02:23:46 this is at cep60148 i think we saw this earlier on at the second of february and you can see there in the second paragraph it's the paragraph i read to you earlier in this morning uh reyna bonds zinc pattern of paint finished

02:23:58 finished acm aluminium composite material so that's how the quotation ended up uh those questions we can see you say are for a

02:24:08 are for a rainy bond acm panel aren't they correct yeah

02:24:12 yeah can you tell us why you didn't provide a quotation that you were asked for in the lead business specification for vinc zinc sorry zinc cm no

02:24:25 i don't recall why why this the the the it says it's a zinc patina i don't recall the reason behind that right there was one must have been one but i don't recall why that was the case

02:24:37 but i don't recall why that was the case you see the specification i showed you that mohic had sent you didn't ask for an acm product at all so the question is why were you quoting for one

02:24:46 i don't nicole and it didn't ask for a rainy bond or iconic product at all did it say again why were you quoting for one i don't recall why that's gone out like that or what the

02:24:57 that's gone out like that or what the reason behind it was right now if we go to your second witness statement please cep three zero six four two four six four two four seven at page 13. i just want to look at paragraph 62

02:25:09 to look at paragraph 62 in the light of what we've just been looking at is in paragraph 62 you're asked the question under the heading do you agree that you put rayna bond forward answer no i did not put reyna bond

02:25:21 answer no i did not put reyna bond forward

02:25:23 forward i understand that raynaud was one of the alternatives named in the specification now the specification i think you're referring to there is the nbs specification um done as part of the tender process

02:25:34 um done as part of the tender process later in 2013 and not the specifications sent to you by lead bitter in early 2013 but it's not correct is it to say that you didn't put rayna bond forward

02:25:45 you didn't put rayna bond forward we can see the quotation you sent originally to leadbitter and you did put raynerbond forward when you hadn't been asked for it that's right isn't it

02:25:56 yes it would have been on that basis

02:26:01 now in february 2013 when you put that quotation forward to mohit kitechat ledbetter you knew that you were quoting for a high-rise building

02:26:12 high-rise building in other words over 18 meters in height correct

02:26:16 correct and you were doing so in circumstances where you were proposing a different product from the one that mr kotecha had asked for yes correct yes did you investigate at that time so late

02:26:28 did you investigate at that time so late january early february 2013 when responding to the request for a quotation from mr kotecha whether the raino bond acm panels that you are quoting for were

02:26:39 panels that you are quoting for were suitable

02:26:40 suitable for a building over 18 meters i didn't know

02:26:46 why is that i i don't i don't recall did you ask anybody at arconic whether it was suitable for a building over 18 meters not unaware of no did you check at all

02:26:58 not unaware of no did you check at all whether it was a suitable product to be used at that height i personally didn't um on the basis that renault on the iconic had been at the meetings i uh yeah i never considered that question

02:27:10 uh yeah i never considered that question you never consider that question

02:27:14 right

02:27:17 okay i want to explore with you a little bit of what you understood deborah french knew about grenfell being a tall building can we go to cep3048975 please

02:27:36 this is an email of the 24th of january 2013 uh to neil wilson

02:27:47 uh to neil wilson at cep and also to deborah french and you're sending on to them the inquiry made by mohu kotecha of the

02:27:58 the inquiry made by mohu kotecha of the 24th of january that we saw a few minutes ago in your evidence together you see that correct yes yes uh now there's no message in your email in

02:28:09 now there's no message in your email in which you forward mohikitecha's email to debbie french or neil wilson um why is that i was just falling on the the information i didn't

02:28:22 the information i didn't believe there was any other message to add to it or just sending that information over to neil wilson and debbie french was debbie french

02:28:33 debbie french was debbie french expecting

02:28:34 expecting the request for quotation specification and drawings at the time i'm not sure whether she was expecting right did you have a conversation with debbie french about

02:28:46 french about this project and the possibility of a design manufacturer and supply at this time with debbie french not that i recall but she'd been at the meeting when um

02:28:58 she'd been at the meeting when um lead bitters were there in in october what did you think she was expecting to do with the information when you sent it to her um

02:29:13 review it in in some depth

02:29:18 review it in some depth and and pass any information on that we may need right to your knowledge was debbie french aware from this email and the attachments if not before that the building

02:29:30 not before that the building grenfell tower was over 18 meters in height i would expect so yes

02:29:40 and is that because we can go to them if need be that the attachments included the specification and drawings of the building

02:29:46 building which make it clear that it is a building over 18 meters in height correct

02:29:54 given that and obviously we need to explore this with her to be fair to her but given the on the face of it she was being given information that would lead her to know that grenfell tower was a

02:30:05 that grenfell tower was a building in over 18 meters in height would you expect her only to provide prices for materials or products

02:30:12 products which was suitable for buildings of those dimensions yes can we then move on to february 2013. we we're at the beginning of it um

02:30:27 if we go to your second witness statement paragraph 10 please page 10 sorry page 10 paragraph 48

02:30:36 you say i understand that iconic and deborah french were fully aware of the building size given that they had received the relevant documents is that a reference to the email of the 24th of january 2013

02:30:47 24th of january 2013 and the attachments that we've just seen i believe it would have been right let's move on in time a little bit in february 2013 cep60150 please

02:31:02 this is an email from you to deborah french of the 27th of february 2013. grenfell tower london is the subject morning debbie ref the above project i have a meeting with the architect studio e on monday 4th of march

02:31:15 studio e on monday 4th of march regarding the rain screen over cladding they've advised me that due to the cost of zinc rain screen they are now considering alternative material and finishes to that of zinc we'll propose your full rainer bond

02:31:26 we'll propose your full rainer bond range and finishes as alternative options

02:31:31 now it's clear from that that you were planning at least at that stage to go to a meeting with studio e on the 4th of march as we can see did you actually go i believe it yes

02:31:42 did you actually go i believe it yes correct

02:31:43 correct it looks as if deborah french was not invited to that meeting is that right correct and you say in the last sentence we'll propose your full reyno bond range and finishes as alternative options

02:31:55 and finishes as alternative options by we do you mean cep yes so did you mean by this email that you were going to be promoting the full reiner bond range and finishes to studio e essentially on behalf of deborah french

02:32:06 essentially on behalf of deborah french yes

02:32:09 had anybody asked you at that stage to put reyno bond forward no so you were doing this voluntarily effectively on behalf of cep well for doing debbie

02:32:21 on behalf of cep well for doing debbie french

02:32:22 french for debbie french yes yes no i'll let you continue well did you consider putting forward cladding from any other manufacturer

02:32:33 cladding from any other manufacturer or providing any alternative options to studio e for example a luco bond no why is that we'd already introduced renabon to the project we dealt with both luca bond and

02:32:46 we dealt with both luca bond and renault bonds the two principal acm companies

02:32:49 companies we dealt with them both on an even basis um and it was courteous in our mind that we stayed with the one would introduce rather than bring another competitor in

02:33:01 rather than bring another competitor in well that why had you introduced debbie french iconic to start with initially because

02:33:05 because i believe they had the zinc product that the studio was looking for did a luca bond not have that

02:33:12 that i'm not aware whether they did or they didn't did you investigate no why is that initially i i was aware that renault had won and and went with that decision right

02:33:24 and and went with that decision right but if you've been even-handed or equal between them you would have wanted to believe we didn't have an account with the luca bond at that time right so did that play into the decision as to whether to be possibly

02:33:35 as to whether to be possibly right

02:33:39 i see now if we go to your

02:33:43 second witness statement uh at page six please i just want to show you something you said paragraph 31

02:33:55 you say under the heading use of rainer bond 55 on grenfell tower i did not discuss or agree with arconic harley or any other party that i or cep would recommend raynerbon 55 cladding

02:34:07 would recommend raynerbon 55 cladding for use on grenfell tower now in the light of the emails we've just been looking at mr blades that's not correct is it i didn't recommend uh renault bond i once i recommended it

02:34:19 uh renault bond i once i recommended it i

02:34:19 i introduced it well you were putting it forward but didn't it for yeah but i wouldn't say a category that they recommend that you should use that right so would we we would draw a distinction would we when reading that between recommending

02:34:31 when reading that between recommending and

02:34:32 and suggesting yes what is the distinction can you help me uh if it was recommended i think i will be endorsing it to use that

02:34:40 that solely and no other product that i was aware of i would recommend a recommendation right but by putting forward or promising that you would propose a full renault bond as you told every

02:34:51 full renault bond as you told every french you would were you not recommending reinaborn 55 cladding for use on grenfell tower no i i don't believe i was recommending that sort

02:35:01 that sort i was in showing uh studio e or introducing studio into other finishes um that may be suitable in like the the thing that the zinc

02:35:13 in like the the thing that the zinc option had it did you know it wasn't it wasn't meeting their cost parameters or their client cost parameters right but you do agree uh that uh you agreed or discussed with arconic that

02:35:24 agreed or discussed with arconic that you would propose rayna 155 cladding for use on grenfell tower

02:35:29 we've just seen that in the yes right

02:35:35 and by proposing something i have to suggest to you that that's that's the same as a recommendation

02:35:45 okay that's right that's not how i would recommend

02:35:49 recommend it all right let's look at march 2013 the story continues uh you meet with mr sons and mr jess of studio e

02:35:58 e on the 4th of march do you remember that meeting

02:36:02 meeting on the 4th of march yes yes and let's go to art 60919 please

02:36:15 this is an email chain between alan dawson of artelia i'll just wait for it to come up and uh and bruce sones

02:36:26 uh and bruce sones cooperative david hale on the 4th of march 2013 david hale was at apple yards and the attachments are greenfield tower regeneration product bream value

02:36:37 regeneration product bream value engineering and uh in the if you go to the second email

02:36:43 email down on that page the very bottom of the page

02:36:48 page you can see there's an email

02:36:55 there which continues on to page two

02:36:59 and i just want to show you the fourth bullet point on that page

02:37:06 is there we have had cep come in today to discuss the cheaper acm cladding option and they will be forwarding samples

02:37:13 samples for possible presentation to planning from our conversation with cep we feel there might be scope to switch from zinc but it will require a bit more elaboration than the lead bitters figure allows

02:37:24 allows we note that ledbetter don't appear to have costed the zinc and have put in a budget figure only was it you who attended that meeting with studio e on the 4th of march yes you did and and at that meeting um

02:37:37 yes you did and and at that meeting um did you have discussions with mr sones about using reyno bond acm yes and did you do so as a cheaper option cheaper than the zinc

02:37:48 cheaper than the zinc that they were after in i wouldn't put it forward as a cheaper option um

02:37:55 option um it was apparent from the conversation or the telephone call where uh studio requested to go back down they they suggested the the zinc was too expensive for the

02:38:06 the zinc was too expensive for the client

02:38:07 client um or it was it was too expensive on cost or whatever the reason was um so i went into it you know to put forward

02:38:17 forward other options that i considered were probably less expensive than zinc on that basis right i don't know how much does it think was something to say we'd never quoted you know never looked at sync as

02:38:28 quoted you know never looked at sync as it cost was it your general experience that

02:38:31 that clients uh tended to choose acm because of budgetary constraints no no can we go to mr says witness statement

02:38:45 well actually before i ask you that i will show you that can i just ask you at this meeting uh where it says according to mr sainz's note that you'd come in today and discuss the cheaper cladding option

02:38:58 and discuss the cheaper cladding option and they'll be forwarding samples can you tell me what do you recall was mr sainz's reaction to the idea of changing zinc and using acm instead

02:39:09 zinc and using acm instead terry can you just repeat that yes what was mr sam's reaction to this to the idea of changing from zing to acm i i don't think i i i don't rico but i

02:39:22 i i don't think i i i don't rico but i don't believe he had any objections to it right okay can we go to his statement sea 301473 please

02:39:31 please and i want to go to page 88 and look at paragraph 207

02:39:42 now he says four lines down from the start of that paragraph uh in preparing this witness statement i am reminded that harley in fact later said that in its experience

02:39:54 its experience clients tend to adopt the cheapest clouding option due to budget constraints and i believe that jeff blade's cep also indicated something similar to me at some point do you recall making a

02:40:06 at some point do you recall making a comment to mr sones that clients tend to adopt the cheapest cladding option because of budget constraints no you don't

02:40:13 don't you don't

02:40:22 at the time and this is march early march 2013 did you think that there were good there were reasons to choose acm other than budgetary constraints

02:40:37 yes what were those um the acm has a paint finish in whatever format pdf or however it is so the client and the the

02:40:49 however it is so the client and the the the design team can choose any particular color they want and and they can match in this since they could match the panels to the aluminium windows if you saw chores and that's one of the advantage of a paint finished

02:41:00 finished product was that discussed at the fourth of march meeting do you remember i don't remember flexibility in terms of choice possibly possibly you say possibly i don't recall what was said at that meeting

02:41:12 what was said at that meeting right um in no i don't recall what was said

02:41:18 you don't recall what was said to that extent i mean it was a discussion about options other than zinc right in that case

02:41:24 case we can see from the bullet point in the email i've just showed you that certainly

02:41:27 certainly budgets were discussed and optionality if

02:41:30 if you forgive the word about finishes was not

02:41:33 not is that a is that a fair i don't recall discussing budgets right with studio a right can we go to cep60151

02:41:47 right can we go to cep60151 this is an email from you to deborah french on the 5th of march the day after your 4th of march meeting with mr sainz and you are uh reporting to her the meeting that

02:41:59 uh reporting to her the meeting that you'd had the previous day with mr sames and indeed adrian jess at studio e and you start by saying hi debbie positive meeting yesterday with adrian jess and bruce sainz of studio e

02:42:11 jess and bruce sainz of studio e what did you mean by that but positive it

02:42:14 it probably went very well it was positive there was

02:42:17 there was whatever however you read positive to me it was a positive meeting positive from whose point of view well certainly from my point of view that they were happy with what i discussed positive

02:42:30 happy with what i discussed positive also

02:42:30 also from debbie french's point of view

02:42:35 yes i would yeah you'd have to ask debbie french whether that was the case but

02:42:39 but i was happy with the meeting i mean you would were you not telling her that it was a positive meeting because you had made some headway with mr sones in the possible selection of rayner bond

02:42:51 in the possible selection of rayner bond products

02:42:53 products yes yes and we can see from the email a bit lower down

02:43:00 down um that um you were asking her from for the provision of information about seeker bonding of rainy bond as concealed fix is being considered for the lower area of rain

02:43:11 considered for the lower area of rain screen and then you ask for a series of samples

02:43:14 samples zinc pattern a stainless look copper patterner and gold look correct all those samples they think is this right well acm weren't they it would have been yes with a pe core i

02:43:26 it would have been yes with a pe core i believe they would have been yes

02:43:32 and can we go to cep60152 this is debra french's response to you in response to this email of the 8th of march

02:43:45 of the 8th of march you see that and she attaches some pictures of a project she's done in cambridge

02:43:51 cambridge with zinc and she starts by saying hi jeff

02:43:54 jeff good to hear the meeting went well

02:43:57 um so she was pleased about the meeting did you send the pictures that she was sending you on to studio e do you remember the one that's at the bottom of the screen uh

02:44:09 bottom of the screen uh no um the attachments if you want we can look at one

02:44:15 but let's let's try um cep 60154 please this is one of the pictures that she was attaching to you of the project in cambridge

02:44:27 to you of the project in cambridge does that look familiar to you i don't recall it but obviously it's an email to me so

02:44:32 me so i would have seen it at the time right did you do you remember whether you sent this picture and others like it onto studio e that you'd received from debbie french

02:44:40 french i don't recall it no now is it right that from this point on say early march 2013 you didn't provide samples or pictures uh or projects to studio e

02:44:51 uh or projects to studio e from any manufacturer other than iconic yes if and i'm not sure i provided those pictures either right

02:45:04 did studio e ask only for our conic samples

02:45:07 samples or did they leave that up to you they only asked me for archon example right can we then go to your solicitor your unsolicited statement

02:45:18 unsolicited statement um cep 50838 please and i'd like to go to page 11 paragraph 7.42

02:45:37 you say there the the purpose of the meeting 4th of march 2013 was to discuss and consider alternative finishes as zinc was now being discounted due to cost issues

02:45:49 being discounted due to cost issues it was considered a matter of courtesy to continue with arconic as it had already been introduced into this project surely mr blades if another manufacturer had offered a better price

02:46:01 had offered a better price you would have pursued it

02:46:06 sorry can you just repeat that question yes if another manufacturer of suitable panels let me put it that way it was offering a better price in comparison with renault bond

02:46:18 comparison with renault bond you would have pursued it i wouldn't have

02:46:21 have chosen another company just purely on price

02:46:26 what else would you choose it on if if in this instance if if another company had a more suitable product more more in line with what pseudoi were considering

02:46:37 considering then i may have considered an alternative panel but i wouldn't go out i wouldn't look at somebody that prices were cheaper or more competitive

02:46:48 prices were cheaper or more competitive than narcotics just to change the product

02:46:53 product when you say it was considered a matter of courtesy to continue with arconic as it already had already been introduced to this project is what you really mean here not courtesy but loyalty to your existing

02:47:05 courtesy but loyalty to your existing relationship with iconique loyalty to them and constitutes them to them because i wouldn't do the same if i'd introduced a luca bomb to the project

02:47:18 introduced a luca bomb to the project i wouldn't then turn around and introduce another acm company to the project right we only had two suppliers of acm i think and if we upset one we're down to one right

02:47:29 to one right and and we've lost let's see 50 of our options i i i understand

02:47:37 so would you accept then that looking at the emails of february and march that we have

02:47:41 have you were actually trying to get rayner bond pe acm panels onto grenfell tower renderbomb panels yes right

02:47:56 well you say renderbomb panels yes i asked you reynabond p acm panels yes but i wasn't the core was never discussed at that point it wasn't a point of sale or or a point of price

02:48:07 of price right it to to cep at the time the pe core was all inclusive with the renault panel

02:48:14 panel hopefully there's no distinction between one or the other all right but rainer bond panels yes you said rainer bond panels yes can we

02:48:28 look at your second witness statement please

02:48:33 please cep3064247 at page six

02:48:38 and look at paragraph 32 um you say and again it's under the same heading we looked at earlier we looked at paragraph 31 i want to look at 32. further and in addition neither i

02:48:51 at 32. further and in addition neither i nor cep recommended reinaborn 55 cladding for use on grenfell tower i introduced deborah french of our connected studio he as being the representative of arconic who could demonstrate their

02:49:03 of arconic who could demonstrate their products however i had no involvement in the discussions in the light of the emails we've been looking at mr blade do you still say that you had no involvement in the discussions about the cladding on grenfell tower i wouldn't

02:49:15 cladding on grenfell tower i wouldn't have been involved in the immediate discussions or the direct discussions with the renner bond archonic panels that was down to iconic dead refrench it was her

02:49:28 iconic dead refrench it was her they were her products to discuss in better knowledge than mine so i i was at the meetings i would have discussed

02:49:38 discussed um the cep rain screen system and how a renault bomb panel may or may not work with it but in terms of the rene bond itself it wasn't my field of knowledge to discuss

02:49:50 wasn't my field of knowledge to discuss it in any great depth as such

02:49:56 but you were involved i think in the discussions between you debbie french and studio e about the choice of planning on grenfell tower

02:50:10 i was at me i was in discussion with them yes yes and indeed you had facilitated or helped to facilitate uh the choice of renault bond panels

02:50:22 uh the choice of renault bond panels on grenfell tower within cep yes the choice of the final panels were down to the architect and the client etc i'd introduced them to them with what i thought was a suitable panel product for that project at that

02:50:35 panel product for that project at that time

02:50:35 time yes and so we need to read paragraph 32 in the light of what you now say okay yes

02:50:44 uh i'd like to turn to an email a little bit later

02:50:48 bit later in 2013 mr blades can we go to cep three zeros four nine seven one nine this is an email for the 13th of may

02:51:00 this is an email for the 13th of may 2013

02:51:02 2013 from deborah french to neil wilson you and roy feuster at cep yep and i'd like to take it take a little bit of time on this email so let's read it all the subject is a

02:51:14 so let's read it all the subject is a bbc report being forwarded and it refers to acm in uae and there's a picture

02:51:25 and it says hi as you may be aware there had been some reports via bbc concerning a fire on a building in uae regarding acm

02:51:36 fire on a building in uae regarding acm as a business we are aware of this report and our technical team are following the details but in the meantime i wanted to add some thoughts that may help if you get questions from your customers stroke clients etc regarding the supply

02:51:50 stroke clients etc regarding the supply of rene bond in the uk as you know we supply both pe and fr core and can control and understand what core is being used in all projects due

02:52:01 core is being used in all projects due to the controlled supply route we have by only supplying rhino bond to a very small group of approved fabricators and working very closely with them on

02:52:12 and working very closely with them on all projects we are able to follow what type of project is being designed stroke developed and then offer the right reynabond specification including the core at this stage we will

02:52:24 including the core at this stage we will continue to offer both pe and fr core and continue the close working relationship we have with our approved fabricators to make sure the right technical support

02:52:36 to make sure the right technical support raynabond specification and materials are being used and installed on rainerbond projects many thanks for making me aware of the reports and for your continued support

02:52:49 do you remember receiving that email i do now yes now it looks from the last sentence that it was cep who had brought the uae fire to deborah french's attention is

02:53:01 fire to deborah french's attention is that right

02:53:03 i i don't recall that right now it's possible

02:53:06 possible to be fair to you that this email was a round-robin email to other

02:53:13 to other fabricators she was telling all of her fabricators the same thing but from your recollection do you remember whether it was cep or somebody else who had become aware of the fire in the uae and had brought it

02:53:25 the fire in the uae and had brought it to her attention i would believe it was somebody else it certainly wasn't myself and i don't recall anybody else at cep

02:53:32 i didn't certainly send anything to debra french right do you recall the fire in the uae which which she's talking about only now i'm

02:53:45 which she's talking about only now i'm aware of these documents now i wasn't aware of it at the time other than three of these documents right so you do we take it from that that you didn't see or hear the reports through the bbc of a fire in the

02:53:56 through the bbc of a fire in the building

02:53:56 building in a building in the uae no i may have seen holding acm i may have seen it after i'd seen this i don't recall

02:54:05 was this email therefore the first that you learned about that fire i believe it wasn't you believe it wasn't

02:54:12 wasn't i think we got i think we got one offer luca bond a couple of days before what a similar message same same sort of email yes right or a similar type of email

02:54:23 type of email they'd seen it on the bbc uh a couple of days before and we got one from the luca bond

02:54:28 bond i see

02:54:32 and who was your contact from a luco bond who you would you got that email for that time it was richard guitar richard

02:54:43 did you understand from this email let's work with this one that the fire was thought to have involved acm with a pe core i believed it was an acm what the call was i wasn't aware of

02:54:54 was i wasn't aware of right did you know about any other cladding fires involving acm or acm with a pe core particularly other than the one we've mentioned at grenfell and not

02:55:06 grenfell and not sorry at camden right did you understand from this that acm with a pe core was combustible

02:55:17 with a pe core was combustible if the if the one that was used in this project was a pe core then yes i would have been right

02:55:24 right following this email mr blades did you consider that acm with a pe call might be a dangerous product for use on a high-rise building because of its in its its combustible properties not

02:55:37 its its combustible properties not if it had been installed with the correct fire barriers and fire strategies that are required with the with the cladding system was that your thought at the time

02:55:50 was that your thought at the time possibly yes i don't recall what my thought of the time was what did you do in response to this email

02:56:01 with regards to

02:56:04 well what did you do internally at cep in response to this we may have had a quick conversation about i don't recall

02:56:12 recall did you start looking more carefully at whether fr cord acm should be specified on particular projects particularly high rise projects in place of pe i i don't recall

02:56:24 in place of pe i i don't recall if we did or not no is there any reason why you didn't start to look more carefully at whether pe was safe to use on high-rise buildings

02:56:37 safe to use on high-rise buildings i'm not aware of a reason why we didn't or

02:56:40 or or did look at it any any further

02:56:46 you say we may have had a quick conversation about it an email came into three people so um you know there could have been a few comments about it was this not a major alarm bell

02:57:00 it was this not a major alarm bell for cep as a manufacturer or as a fabricator of acm panels

02:57:11 it it could have been yes well you say it could have been i i can suggest you it certainly should have been but the question i have is was it it wasn't me personally no well you're personally

02:57:22 personally a recipient of this email what i'm really keen to get to the bottom of is why

02:57:27 why you you didn't you didn't react more strongly to this message and start thinking hard about whether the use of acm pe cord panels were safe on buildings above 18

02:57:39 panels were safe on buildings above 18 meters

02:57:39 meters in the uk we would have relied on designers possibly to to ensure that that product or the products that was being chosen were

02:57:51 products that was being chosen were compliant did this email cause you to look or look again perhaps at the bba certificate for rayner bond acm panels i'm not aware it did i'm not no well to

02:58:03 i'm not aware it did i'm not no well to question it no did you think it was called i don't recall doing that no did any other clients

02:58:09 clients uh or the market or other fabricators in the

02:58:13 the same position as you express any views to you about the fire risks inherent in using pe as opposed to fr core not i'm aware of was there any market

02:58:24 not i'm aware of was there any market discussion beyond this email that you were aware of at the time no we're impossible to have any market discussions about it

02:58:34 mr chairman we're we're approaching one o'clock

02:58:38 o'clock and mid mid line and i'm i'm going to turn to a very slightly different aspect of the same document it may be an appropriate moment to break well if it's not inconvenient to you i suggest that it probably is a

02:58:50 to you i suggest that it probably is a good idea

02:58:51 good idea because these things have a habit of getting along as you initially expect yes this line is probably another 10 minutes so i will eat it

02:59:00 eat it then lip right let's have a break now yes right

02:59:03 yes right mr blaze we're going to have a break now so we can all get some lunch okay we'll resume at 2 o'clock please and remember not to talk to anyone about your evidence or anything to do with it while you're out of the room thank you all right

02:59:15 out of the room thank you all right thank you very much would you go with the usher please

02:59:19 [Music]

02:59:27 all right two o'clock then please

02:59:45 you