RESTRICTED. (SDN / ROTI / Contemporaneous Notes / Index of Interview with VIW / Visually/recorded interview)

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1 Form MG15(T) Page 1 of 21 RECORD OF INTERVIEW Enter type: ROTI (SDN / ROTI / Contemporaneous Notes / Index of Interview with VIW / Visually/recorded interview) Person interviewed: KEYS, DUNCAN ' Place of interview: SUTTONPSTN Date of interview: 20/07/2004 Time commenced: 1236 HOURS Time concluded: 1305 HOURS Duration of interview: 29 MINUTES Tape reference nos. (_) Interviewer(s): DI BOOTH; Other persons present: NONE I Police Exhibit No: Number of Pages: I Person speaking Text I DI BOOTH This interview is being tape recorded. I am Detective Inspector Andy BOOTH from the Specialist Crime Directorate based at Sutton Police Station. The other officer present: Is Detective Sergeant Sean PEARCE and I'm attached to the same unit. DI BOOTH I am interviewing - could you give your full name please, Sir. 2003(l) 1

2 Intervmw of KEYS, DUNCAN Form MG15(T)(CONT) Page 2 of 21 KEYS Duncan Thomas KEYS. DI BOOTH I am interviewing Mr KEYS regarding a telephone call that was made to the Commission for Racial Equality offices in the borough on the 6th May 2004 (06/05/2004). Mr KEYS, before we start the body of the interview I just want to cover one thing: that we have held a pre interview meeting regarding this matter with DCI MCALEENAN in this office, in the DCI's office at Sutton, and that started at I've made some notes with regards to that meeting where I was present and they are Exhibit AB/1. This matter has been explained to you and you did agree that the. lninutes could be taken: is that correct? KEYS Yes, I did. DI BOOTH OK. We also discussed the matter of legal representation during this interview and is it correct at this stage you've decided to go ahead without legal,representation? KEYS That's correct. DI BOOTH Excellent. OK. Mr KEYS, the idea with regard to this incident is once the audio copy is taken, then that will be listened to and transcribed onto an evidential written statement, both of which you'll be able to have access to mad listen to, to make sure that they're correct. KEYS Thank you. 2003(1)

3 Interview o_:keys, DUNCAN Form MG15(T)(CONT) Page 3 of 21 DI BOOTH OK. The interview is taking place in the Detective Chief haspector's office on the third floor at Sutton office at the Specialist Crime Directorate. The date is the 20 th July 2004 (20/07/2004) and I make the time 1236 pm. The purpose of the interview to start off with, Mr KEYS, as we discussed in the meeting prior, I'm going to play you a copy of a telephone call made to the CRE about 0907 am on the 6th May. If you could have a listen to that for me. DI BOOTH commences to play recording: '.... perverted pleasure, again with... MUBARAK was killed because people thought it would be fulmy to see what would happen when they put a young Asian lad in with someone who wanted to kill Asians. Now, MUBARAK wasn't the only victim in there but he was the victim that died. Other people had been... ' DIBOOTH OK. That's an excerpt from a CD ROM which was ) retrieved by a DC MCNEIL from a tape recording facility at the CRE. Do you recognise that voice? KEYS Yes I do; that's me. DI BOOTH And is that the phone call you made on that day? KEYS Yes, it is. DI BOOTH I don't intend to play the whole content of the tape at this stage because you're obviously aware of what you said at the time (1)

4 ;TRICTED Intervmwof.KEYS,DUNCAN FormMG15(T)(CONT) Page 4 of 21 KEYS Yes. DI BOOTH We're here to talk about and to receive information with regards to a process that's been referred to as 'Coliseum' or 'Gladiator' at FELTHAM Young Offenders' Institute. Now let's start off with basics. You made that telephone call to the CRE. Could you first give your position professionally within the Prison Service? KEYS Yes. I'm an assistant secretary employed by the Prison Officers' Association. I used to be a prison officer from '82 to '99 (00/00/ /00/1999). I then left the employment of the service and went full-time for the Union. DI BOOTH In your capacity, who do you represent and what is your remit within that organisation? KEYS Well, I'm a full-time official of the Association. I have responsibility primarily for press, media and membership within the private sector. However, we have a total membership in excess of 35,000 so on many issues we would be representing the entire workforce. DI BOOTH OK. Is that nationally? KEYS Yes, it is. DI BOOTH OK. In the framework and the management tree of your particularpart ot tile POA.vehere do you stand within their 2003(1)

5 Interview of: KEYS, DUNCAN Form MG 15(T)(CONT) Page 5 of 21 management tree? work down to where you - Could you sort of start from the top and KEYS Certainly. The top is the General Secretary, who's Brian CATON. The Deputy General Secretary is below him: that's Mark FREEMAN. There are then four Assistant Secretaries, including myself: Glynn TRAVIS, Jim DAWSON, Derek TURNER, and I make the fourth. DI BOOTH OK. With regards to the telephone call that was made to the CRE, it's obviously going to be discussed at length during the interview. Could you start by informing me, with regards to your position, telephone call? what made you make that KEYS Well, I think just from the short extract that we've just heard, you're very likely to pick up the emotiori that was in my voice as I was making that call. I felt it was just something that I had to do. I had become aware through f. conversation, in particular with one colleague, of a very : serious allegation made against a member of the POA. I had wrestled with my conscience for some time to see whether this information - which part of it I understand others were aware of - was going to leak into the public domain and whether the employer, that being the Prison Service, were in fact going to be made aware of it or indeed the Police. I suppose I could have, on reflection, gone to the Police. I didn't. I phoned an organisation that I knew were heavily involved in the MUBARAK process, and that was the CRE. In fact, I phoned twice: I phoned once at - approximately 5 o'clockthe day before the recording. 2003(1) '

6 Interv:ew of KEYS, DUNCAN Form MG15(T)(CONT) Page 6 of 21 They told me that no-one was available. I wrestled that night again with the information that I had but I felt that not only as a member of the POA and an Assistant Secretary within that organisation, as a member of the human race I felt that if I had information that could be relevant to a very serious enquiry that was shortly to take place, and even more importantly, the death of a human being, that it was my duty to make someone aware. Perhaps I took the coward's way because I didn't front it. I left a message and perhaps I thought other people would just take that information and do something with it. DI BOOTH Yeah. KEYS I'm not here to have a medal pinned on me. It hasn't turned out that way but everything that I said was purely said because of information that had been passed to me and I honestly felt duty bound to pass that information on. DI BOOTH OK. The summary of the telephone call mentions the fact that you were concerned that there was a practice in existence at FELTHAM Young Offenders' Institute which had been referred to as 'Coliseum' or 'Gladiator'. Now briefly that practice would be where inmates, maybe of opposite ethnicity or opposing characters or wills or strengths, would be put in the same cell together and then Prison Officers would bet on an outcome of any fights or angst between the two of them. Is that correct? KEYS That's the information that was given to me. Absolutely --- right (1) 6 124_7

7 Intervmw op KEYS, DUNCAN Form MG15(T)(CONT) Page 7 of 21 DI BOOTH During the telephone call you name a particular person by the name of HERRING as having knowledge of it. KEYS That's correct. DI BOOTH Could you give me some history of the source of your need to give HERRING's name on the telephone call. I mean what do you base that on? KEYS I base that entirely on a conversation that I had with a member of the National Executive who had been at a time and date that I can't recall at the moment, been attending FELTHAM Prison for the purpose of meeting with the Committee. I met him after he left FELTHAM that evening for an evening meal. He told me during the course of our meal that he had some information that he thought was very very important and that he couldn't believe what he had been told in FELTHAM that day. DI BOOTH Right. KEYS I obviously asked him what it was. He again said to me mad as I recall, these were his words, "You're not going to fucking believe what I'm going to tell you". I said, "Well tell me". He told me that in the POA office that day in FELTHAM, Nigel HERRING the Branch Secretary had told him that officers in FELTHAM had been conducting a game called 'Coliseum'. The terms of the 'game" as it was alluded to were that as you've explained people of either disparate strength or comp-ai:at-a-ii_strength or of equal (1)

8 Interviewof'.KEYS.DUNCAN FormMG15(T)(CONT) Page 8 of 21. ethnicity were to be put into a cell together with the anticipation that friction would occur, possibly leading to violence, mad that bets would be taken on that outcome. Nigel HERRING's name that I gave to the CRE were nothing - was nothing to do with my relationship with Nlgel HERRING. I am aware of him; I do know him. But the information that was given to me was very, very particular. It was stark. There was only one name mentioned and that name was Nigel HERRING. Nigel HERRING told Tom ROBSON that. Tom ROBSON then told me and I was in receipt of that information. DI BOOTH OK. What's your relationship with Tom ROBSON? KEYS He's a member of the National Executive and probably my best friend. DI BOOTH Right. And your relationship with Nigel HERRING? KEYS I know Nigel as a branch official at FELTHAM. We've been in each others company; there's never been a difficulty between ourselves. I think perhaps some of his political views and attitudes aren't exactly in line with mine but I also understand, having come from a local branch, that it can be different working in just one establishment and dealing with those problems, rather than looking at the whole picture of the national organisation. DI BOOTH And you were a Prison Officer at FELTHAM, weren't you? 2003(1)

9 Interviewof:KEYS,DUNCAN FormMG15(T)(CONT) Page9 of 21 KEYS I was between '82 and '88 (00/00/ /00/1988). I was then promoted and sent to WORMWOOD SCRUBBS where I served until '99 (00/00/1999). DI BOOTH Did you ever serve with HERRING at FELTHAM? KEYS I don't think so. DI BOOTH OK. With regards to HERRING, on the telephone call it is quite specific, I mean with regards to HERRING's involvement. I mean listening to what you've got to say, do you have any evidence that HERRING was actually revolved in any of the practice? KEYS Absolutely none whatsoever. Tom ROBSON never indicated that. All that he told me was that HERRING had told him that this practice either had occurred or was occurring. I've got no evidence whatsoever that Nigel HERRING took part in any way, shape or form. DI BOOTH Is Tom ROBSON aware that you phoned the CRE? KEYS No-one is aware that I phoned the CRE. I didn't tell my employers. In fact, I didn't tell my wife. DIBOOTH Right, OK. So that's where your foundation for the Coliseum or the Gladiator practice was based. KEYS That's correct. 2003(1) "

10 Interview of. KEYS, DUNCAN Form MG15(T)(CONT) Page 10 of 21 D] BOOTH Now as a result of the meeting we had prior to the interview, we've obviously now become aware that other parties within the National Executive or the POA are also aware of this practice. I mean it's been in newspapers - KEYS Yes. DI BOOTH on a number of occasions. Could you give me your knowledge of meetings that have taken place with regards to the Gladiator or Coliseum practice and where you believe that originated t:rom? Where was the source? I mean your source of the Gladiator was via Tom ROBSON and a pre-meeting with HERRING. Now where does the Gladiator or Coliseum source from within the Executive Committee or the POA? KEYS It's - it appears to have been anecdotal evidence for quite some time. I understand that either 3 or 4 years ago there was a disciplinary case at FELTHAM. I understand also that this case may have gone to trial at Crown Court. Following the internal disciplinary, I understand that a prisoner that was interviewed during the course of the heating made certain accusations that he had been set up by staff in some shape or form. I don't know the ins and outs of it and I know none of the real integral parts of that case. What I do know is that that case was run by another NEC member called Steve COX, and he had that information. It was quite widely known that the prisoner had made certain allegations and from that point on it all sort of melted into the background. I understand that the staff were either... remstatedor moved on, whatever, and the POA opened (1)

11 Intervmw of KEYS, DUNCAN Form MG 15(T)(CONT) Page 11 of 21 another chapter in its book and got on with more work "the next day. DI BOOTH OK. KEYS When I received the information from Tom ROBSON I must admit that the slight bit of knowledge that I had about the previous instance did come to my mind. However, it was quickly acknowledged by the National Executive who had also been picking up information on the field because Prison Officers, like many people, gossip. They pass information up that they may think is relevant. And others had received information regarding Coliseum. I understand that it was of such concern that the National Chairman and General Secretary wished to speak to the FELTHAM Committee in advance of the public enquiry so that they could ascertain whether in fact the Committee were aware of these allegations and, if they were, what could they impart. DI BOOTH Who are the National Chairmen? KEYS The National Chairman is Colin MOSES and the General Secretary is Brian CATON. DIBOOTH OK. KEYS I understand that there was some reluctance on the part of the FELTHAM Committee to come to the POA Headquarters called Cronin House in EDMONTON to... discuss this matter: They wished for far more information (1)

12 Interview of. KEYS, DUNCAN Form MG 15(T)(CONT) Page 12 of 21 about why the meeting would be called, rather than the rather bare and non-specific invitation that they had received. This caused, I'm aware, considerable concern amongst the National Executive and I understand that, because of FELTHAM's reluctance to come to this meeting, a decision was made to raise the issue with Phil WHEATLEY, who is now the Director General of the Prison Service, I believe Martin NAREY, who is the head of NOMS, and I am - I understand but I'm not certain that possibly the Minister as well. However, I'm uncertain of that point. DI BOOTH And the Minister would be -? KEYS Paul GOGGINS. I understand that information was passed to the Director General of the Prison Service by those POA members that attended that meeting. Principally because the POA would obviously abhor such behaviour by any of the membership if the allegation were true, and also as a responsible Trade Union they needed to make the employer aware of this very significant information at the earliest possible opportunity and I understand that that's what the POA did. DI BOOTH Right. Now you mentioned the FELTHAM Committee. Now did the FELTHAM with the NEC? Committee ever attend a meeting KEYS They were invited, I understand, to two, possibly three meetings. What I understand transpired was-that rather... thari a meeting with the full National Executive or indeed a (1)

13 Intervmw of KEYS, DUNCAN Form MG 15(T)(CONT) Page 13 of 21 section of them referred to as 'the officers of the Association' who were principally the National Chair, the General Secretary, the Deputy General Secretary, two Vice Chairs,and the Finance Officer. They, in fact, ended up meeting with just two members of the executive. That was because the day of the meeting actually coincided with a full NEC meeting. They met with the General Secretary Brian CATON and a Vice Chair called Steve GILLON. They, I understand, met at Cronin House with members of the FELTHAM Committee. I can't tell you who was there or how many but I know that the meeting took place. DI BOOTH Right. KEYS There was a report back subsequent to that meeting given by both Steve GILLON and Brian CATON to the National Executive and I think I'm right in saying that I may have taken a note of that part of an NEC meeting. DI BOOTH So you'd have been present at that meeting. KEYS At the feedback meeting, yes. My understanding is that there were several issues raised with FELTHAM, some of them internal matters, about communication with the head organisation. But principally an issue was raised regarding Coliseum and I understand that that matter was put to members of the FELTHAM Committee. Of those present, one, I believe stated that he was aware of the rumour but added a caveat that he believed that such a rmnour had only started after the MUBARAK murder and not prior to it. 2003(1) 13 :z.24s4:

14 Intm\qew of KEYS, DUNCAN Form MG15(T)(CONT) Page 14 of 21 That matter was reported to the National Executive by way of the feedback from the two NEC officials. DI BOOTH Al_d this would have been after you'd made your phone call to the CRE? KEYS I'm not certain on the dates, but I would have presumed so. DIBOOTH OK. Now - so with regards to the FELTHAM Committee, are you aware of any members - of the names of any of the members that would have attended that meeting? KEYS I only know one other by name member of the committee. His name is Stuart SIBBICK. Whether he attended or not, I really don't know. But the only two that I know, principally because they're the Chair and the Secretary, are Nigel HERRING and Smart SIBBICK. DI BOOTH Right. I'm just going to back-track again. With regards to your - the meeting with Tom ROBSON - KEYS Mmm. DI BOOTH do you remember when that would have been? About what time? KEYS Well, I know that it was in the evening and I know that we were in a public house that's a restaurant, goes under the q name of the Hungry Horse in ASHFORD. 2oo?(1)

15 Interview of KEYS, DUNCAN Folrn MG15(T)(CONT) Page 15 of 21 DI BOOTH I'm just looking for the time. KEYS I suppose we would have been in there around half six - seven o'clock ( hours). DI BOOTH The date. Do you remember? KEYS No I don't. I don't remember the date. DI BOOTH About how long ago would it have been? KEYS Quite some time. Possibly I'm guessing, but possibly around 10 months. As long ago as that. DI BOOTH Between 6 months and a year maybe? KEYS Yeah, yeah. DI BOOTH OK. With regards to you're saying that Colin MOSES became aware, maybe just from rumour, that this Coliseum or Gladiator practice was in existence. With regards to the discipline matter that went to Court, was the actual term 'Gladiator" or 'Coliseum' mentioned at that discipline hearing? I'm trying to source where this actual name has come from. I mean it's been mentioned to Tom ROBSON by Nigel HERRING, we believe. But I'm guessing that prior to that, if the members of the NEC or the Senior Management are aware of its existence, where is it sourced from, do you believe, other than coming from Nigel HERRING's words? 2003 ( 1)

16 RE;TRICTED Interviewof: KEYS,DUNCAN Form MG15(T)(CONT) Page 16of 21 KEYS Well, I personally have never heard of Coliseum or Gladiators from any other source than Tom ROBSON and fi'om what he told me Nigel HERRING said. I'm completely unaware of whether the inmate involved mentioned such a practice by name. And I'm also I'd also say that Colin MOSES, I think, was aware of rumours, not that it was actually occurring. However, the rumours were of such a serious nature that he had no alternative as Chairman of the Association than to make it known at a very high level. DI BOOTH I'd previously written on a note from our meeting prior to the interview that, after the invitation for the FELTHAM Committee to the Headquarters to discuss the matter, there was then a meeting involving Mr WHEATLEY and NAREY. Now was that the day after that this - KEYS I understand that was the day after they didn't attend the meeting with the Executive. DI BOOTH Right. And at that meeting between Mr WHEATLEY and NAREY, were you at that meeting? KEYS No, I was not. DI BOOTH Was it at that meeting that subsequent invitations were put forward to the FELTHAM Committee to attend? KEYS Yes, I understand that's right. 2003(1) B7

17 Interviewo1:KEYS,DUNCAN FormMG15(T)(CONT) Page 17 of 21 DI BOOTH At which meeting if we could just clarify at which meeting you were at which you wourt have taken a Minute that the Coliseum or Gladiator practice was discussed. KEYS Right. That would have been a National Executive Committee meeting after Mr CATON and Mr GILLON had met with members of the FELTHAM Committee. I would have been at that meeting in my capacity as an Assistant Secretary and would probably have taken a note of the meeting for part or all of it. DI BOOTH Do you remember what date that was? KEYS No, I don't. DI BOOTH Any I mean I'm looking to try and get a time-line with regards to it. Now with regards to your meeting with Tom ROBSON that was maybe 10 months ago, could you give us a figure? KEYS Probably within the last 4 months, I would suggest. DIBOOTH OK. Was the term 'Gladiator' or 'Coliseum' actually mentioned at that meeting? KEYS Yes it was. DI BOOTH See, I'm trying to - as I've said before, I'm trying to source where this name has been attached. Now if HERRING has mentioned it to Tom ROBSON and... ROBSON your friend has mentioned it to yon, where or 2003(1) _--

18 Interviewof KEYS,DUNCAN FormMG15(T)(CONT) Page 18of21 how have the Committee been aware that that is the name that's been attached to this practice? KEYS I think just through rumour and gossip that has generated itself through the - through the Prison Service. It certainly appeared that other members of the Executive had some idea of the practice. Maybe not in graphic detail, or certainly not in graphic detail. Some of them probably had never heard of it, others had been made aware of something, some people might have been giving it the name of 'Gladiator', some people may have corrupted that to 'Coliseum', or the other way round. It seemed a bit of a mish-mash but there certainly did seem to be some lmowledge amongst some people. DI BOOTH Right. So you took the Minute at the NEC Meeting and then we believe that that was then reported to Mr WHEATLEY. KEYS Yes. DI BOOTH OK. I mean you were a Prison Officer for some time. I mean were you ever aware in your capacity of such a practice taking place? KEYS Absolutely not. I mean I - I suppose that when - that's part of the reason that I took the ultimately the action that I did, that I was actually horrified that such a practice could be in existence. Again, I'd have to say I've got no evidence whatsoever that this practice did occur or didn't... occur oo3(1)

19 Interview of KEYS, DUNCAN Form MG15(T)(CONT) Page 19 of 21 DI BOOTH Yeah. KEYS What I had was information that was of such a serious nature that I believed I had to make the authorities aware of it. DI BOOTH Because on the actual recording of the telephone call, you're very strong around the issue that you believed that this practice was in existence and was a cause of Zahid MUBARAK's death. ' KEYS Well, I can explain that, I suppose to some extent, that that might be my amateur detective role in this. And maybe I'm putting a scenario of 2 and 2 together and coming up with 5. It did seem to me that if the allegation was true, that inmates of varying ethnicity were being put in cells together with the soul reason being to cause conflict, and then you looked at MUBARAK and STUART being in a cell and the tragedy that ultimately occurred from that, maybe that's what I based that on. DI BOOTH Mmm. KEYS Now I've got nothing to base that on other than my own amateur method of constructing that scenario. It just haunted me that that in fact may have been true. DI BOOTH Yeah. 2003(1)

20 Interviewof KEYS,DUNCAN Form MG15(T)(CONT) Page 20of 21 KEYS Aaadthat's why I think, when you listen to the tape, I say it with a passion, I think, because I just found it the most distressing information. Because if it's true and if I had been given this information that ultimately was proved to be correct, there could be staff that were involved in a Conspiracy to Murder, which I think is the most absolute worst thing that Prison Officers could be involved in. And I still feel that strongly now. I have got no wish whatsoever to put myself in a difficult position with members of my association, the vast majority of whom are very good public servants. But I also have a duty as a member of society and if I'm made privy to that information and if, on balance, I believe that I have to make people aware of it, then I'll do it again. DI BOOTH I mean you're obviously aware of the public enquiry into the death ofmubarak - ICA_YS Yes, I am. DIBOOTH - which is being held by Lord Justice KEITH on September the 6 th. Now we've also explained the availability or the contents of this interview and if there are calls by the public enquiry, then the telephone recording itself would be made available to the enquiry, and that's partly the reason why you've decided to make a statement. I mean the matter i_ in the public domain. (Tape end signal) 2003(1)

21 Interview of KEYS, DUNCAN Form MG 15(T)(CONT) Page 21 of 21 This tape is just drawing to a close, the time being 1.04 pm (1304 hours) 2003(I)

22 Form MG15(T) Page 1 of 10 RECORD OF INTERVIEW Enter type: ROTI (SDN / ROTI / Contemporaneous Notes / Index of Interview with VlW / Visually recorded interview) Person interviewed: Place of interview: KEYS,DUNCAN SUTTON PSTN Date of interview: 20/07/2004 Time commenced: 1305 HOURS Time concluded: 1321 HOURS Duration of interview: 16 MINUTES Tape reference nos. (-_) Interviewer(s): DI BOOTH; Other persons present: NONE I Police Exhibit No: Number of Pages: I Person speaking Text [ DI BOOTH This is the continuation of the interview with Mr Duncan KEYS in the Detective Chief Inspector's office at Sutton Police Station. DI BOOTH speaking. Also present is and Mr Duncan KEYS. The time is 1.05 (1305 hours). We've just had a minute to change the tapes and have a fresh pair in. I'll just confirm, Mr KEYS, whilst we've been changing the tapes nothing untoward has happened during the interview. KEYS That's correct. 2003(1)

23 lntervww of KEYS, DUNCAN Form MG15(T)(CONT) Page 2 of 10 DI BOOTH OK. What I was trying to say before the last tape finished abruptly was, it's in the public domain and there have been articles regarding the public enquiry and the Gladiator or Coliseum practice in tabloid newspapers. Have you any idea of the source of the information to the newspapers? KEYS No, I don't. I know that the matter was discussed between senior members of the POA National Executive and the Prison Service. My own judgement would be that if anyone had leaked it, it would have been the Prison Service. I've got nothing to back that up with but I certainly know it wasn't me because I hadn't told anyone. It could either have been the Prison Service or, I presume, the CRE. Those were the only people in possession of the knowledge, apart from myself, at that time. DI BOOTH Yeah. I mean with a professional nature in mind, making the telephone call to the CRE was a very big step for you to make. KEYS Yes, it was. DI BOOTH Now what position does that put you in with your organisation that you went to the CRE first, rather than actually going to maybe your General Secretary? KEYS It could put me in a difficult position. I - I suppose I reacted in some ways on - on an impulse. I was concerned that information that I had might not filter through. I also believed that members of the employing body for myself were actually aware of this rumour and it hadn't seemed to go anywhere, and I just had an overriding sense that I needed to make someone aware of it that would do something with it. I knew... that th---ecre were obviously heaviiy involvect both in the original (1)

24 Intelvlewof KEYS,DUNCAN FormMGI5(T)(CONT) Page 3 of I0 I murder enquiry and subsequently in the public enquiry. I thought that they would be able to access and tap into the right people that this information should rest with. Again, that was probably a very naive action for me to take. It may have put me in conflict, not only with my employers but with elements of the membership who might not believe that I was acting in the best interests of the POA. But I have to believe that if our association stands for anything, it stands for right and it stands for truth and if ultimately that is what is achieved from that information being given, then so be it. DI BOOTH With regards to knowledge of the allegation that this practice is in existence, if we could just run over a couple of names so that I can sort of summarise the issue. The two National Executive Committee members that were there with the FELTHAM Committee that would have received the admission, if you like, off of the one Committee member that he or she was aware of the Coliseum of Gladiator practice, their names were -? KEYS That was Brian CATON and Steve GILLON. DI BOOTH And they are based at -? KEYS CRONIN HOUSE in EDMONTON. DI BOOTH Who of other - I'll refer to them as Senior Management - who of the other Senior Management members would also be aware of that admission? KEYS Well, virtually the entire National Executive that were present at the meeting held where a Minute was taken following the report back by... those two people, and they would all be-named in that documentation_ (1) '"

25 lntmwlew of KEYS, DUNCAN Form MG15(T)(CONT) Page 4 of 10 DI BOOTH I mean from memory, can you list how many - give me names or how many that is likely to be? KEYS That would probably be around potentially 22 / 23 people if everyone had turned up for the meeting. DI BOOTH Do you specifically remember, sitting here now, members that were present? KEYS No, I don't. DI BOOTH OK. The Minute that you made, what would have been the paper trail for that? Where would it have gone? KEYS Right. It would - the Minute would have been given to one of the secretarial staff to turn into a POA document. That would then come back on a - the next normally NEC Meeting where any amendments would be made to that and, finally, ratification for the document would have been given. DI BOOTH Is there any way for example, is it something that you would then sign or put your mark on? KEYS It would be for the National Chairman to sign as correct, and those Minutes would then be circulated to the membership via their Branch Committees. DIBOOTH So when you refer to 'the Membership', you're talking of Prison Officers. 2003(1) _6"

26 Interviewof KEYS,DUNCAN FormMG15(T)(CONT) Page5 of 10 KEYS Yes. DI BOOTH So in essence the mention of this Gladiator or Coliseum practice at that meeting where you took the Minute, could have been then diverted and divulged to every member of the POA. KEYS Well, what I would say is, the Minutes were carefully constructed in that a practice was referred to, but certainly not specifically as I recall. I mean I'd have to have the document in front of me. But usually what happens, if a set of Minutes go out where a section of the membership are uncertain as to what they actually refer to or what they actually mean, they would then speak to their National Executive member for some clarification. So it's certainly possible that a matter such as this would have been widely discussed. DI BOOTH I mean if we wanted to get possession of a copy of those Minutes, how would we go about that? What would be the process of doing that? KEYS Well normally, if you - P DI BOOTH I'm looking to try and put it down to a particular date so that we can be sure that the meeting that you're referring to - KEYS Well, all of the Minutes are held centrally on computer at CRONIN HOUSE, and also in hard copy. So you would merely have to contact the General Secretary who would make Minutes for a specific period that you'd requested available to you. DIBOOTH Are you aware of this practice being present on any other - - documentation other than theminute from thatmeeting?--_ (1)

27 IntervJewof. KEYS,DUNCAN Form MG15(T)(CONT) Page6 of 10 KEYS No, I'm not. DI BOOTH I mean since your phone call it's obviously something you feel very strongly about, and from a moral point you should be applauded. Have you done anything proactively about it since you made the telephone call? KEYS No I haven't. I haven't spoken to any members of the Executive, any members of my family whatsoever, or any other organisation. DI BOOTH OK. And I'd just confirm as we sort of near the end of the questions I've got to ask, that you have no personal argument with Nigel HERRING? KEYS Absolutely not. Nigel HERRING is Branch Secretary at a very busy, healthy branch, and I have no axe to grind with him whatsoever. Again, if I have to apologise for anything, it's that I took a - what could be viewed as a coward's way out. Perhaps I should have gone direct to the Police; perhaps my Association should have gone direct to the Police; perhaps Phil WHEATLEY should have gone direct to the Police. There are lots of 'ifs', 'buts' and 'maybes' in here. What I was concemed about is both the reputation of the Prison Officers Association and its 35,000 members, and the potential that someone actually did what was being suggested. Nigel HERRING, I was not told had any role, any involvement whatsoever in that practice. What I was told, though, and what I would stand by in any place at any time, is that he was aware of it. Now that's a matter for him and how he wants to deal with that. I dealt with it in a particular way and I may be criticised for that. However, I just felt that I needed to bring that knowledge,to - to the - - public: (1)

28 Intelvlew of KEYS, DUNCAN Form MG15(T)(CONT) Page 7 of 10 DI BOOTH Other than Nigel HERRING, are there any other members of the NEC that you have maybe a personal issue with? KEYS Absolutely not. I'm I work for an Association that I've belonged to for some 22 years. I love the job that I do. I like to think that I'm good at the job that I do and that I assist the membership, and I'm one of those fortunate people that enjoys nearly every day that I go into work madi wouldn't do anything that normally would jeopardise that position. The people that I work with are people who have been in the main elected bythe membership to perform a role. That's no - of no interest to me, who's elected and who isn't. I get on well with all of them and I have no axe to grind with any members of the Executive. DI BOOTH With regards to content of this interview, I've got no questions. But I feel it's important that you have an opportunity to say anything that you'd like to say before we then transcribe the audio copy of this into a written statement, which you've been aware may be made available to public enquiries or into the public domain. But that's obviously something we discussed with Mr MCALEENAN. Is there anything else that you'd like to say before we conclude the interview? KEYS Well, I'm grateful for the opportunity to be with you today. I suppose I half expected that tlfis moment might come. I didn't run to any newspapers or try to seek some political value out of this. As I've already said and I don't wish to over-egg the pudding or repeatedly state it, perhaps I made an error of judgement in where I took that information. My sole purpose, my only intention, is that I just couldn't live with that knowledge and think that it wasn't going to go anywhere and that a public enquiry into this awful tragedy would not have the... opportunity of everrhearing this information. I hope and I pray that 2003(1)

29 REt ;TRICTED Interview of KEYS, DUNCAN Form MG15(T)(CONT) Page 8 of 10 what I was told was rubbish, that it was absolutely untrue and that the person responsible for it has a real shake-up and learns that what they said can come into the public forum, because I know that the impact it's going to have on me and potentially my family and my friends, could be quite substantial. But there is no way that I could be given that infon_ation and be left in a position where I didn't feel that it was going to go anywhere, becanse if it is true, how would I feel if I were in the position of those parents, if it was true that the Prison Service actually did that to their son? Well, I couldn't live with myself, knowing that knowledge. So I'm there to be kicked; I'm there to be criticised. But I think the overriding principle that I've had in this is to tell the truth and tell people that can do an investigation and can get answers. As I say, I hope that it's all rubbish. I really do. If it isn't, then the Prison Service has got an awful lot of self-examination to do and I'm grateful for the opportunity to speak to you. DI BOOTH Sean? I'll just ask one thing. From your experience obviously as a Prison Officer, on a practical basis in your opinion, could it be possible to actually do that, to put people together like that? I mean - and if it were, would it have to involve a number of people from different departments working in collusion? Would you be able to make any sort of comment on that in your experience of it? KEYS Predominantly the allocation of cells is done at the lowest level because it's not really a job that requires a lot of seniority unless there are specific details amongst the inmates that are already known. For example if someone is a suicide risk, if they have a particular medical complaint or if they're a sex offender or a vulnerable prisoner. Then -.L (1) _0

30 intmvmwof KEYS,DUNCAN FormMGIS(T)(CONT) Page 9 of 10 obviously that would be on their record and people would put them in an appropriate place. Yeah. KEYS If none of those circumstances pertained at that time, then my understanding would be that people would be allocated as an officer saw fit. So if I was to go into a prison establishment and they decided to put me with Inmate B, then that's where I would go. So it could be down to an individual officer potentially to make a - KEYS Certainly, there's no my - my experience says that there is no chain of command that would actually operate such a function. It's a very basic low-level function. Someone comes in and, to put it crudely, if there's a door with no-one behind it, then that person goes in. Right. KEYS And that's it. OK, thanks. DI BOOTH OK, Mr KEYS. The time is 1.21 pm (1321 hours). I intend to conclude the interview now. KEYS Thank you. 2003(1)

31 Interview of KEYS, DUNCAN Form MG15(T)(CONT) Page 10 of (1) '52 - I

32 Form MG15(T) Page 1 of 24 RECORD OF INTERVIEW Enter type: ROTI (SDN / ROTI / contemporaneous Notes / Index of Interview with VlW / Visually recorded interview) Person interviewed: Place of interview: ROBSON, TONY EDMONTON PSTN Date of interview: 22/07/2004 Time commenced: 1420 HOURS Time concluded: 1445 HOURS Duration of interview: 25 MINUTES Tape reference nos. (--_) SCP/1 Interviewer(s): ; DC HEADLEY Other persons present: NONE I Police Exhibit No: SCP/1A Number of Pages: I Person speak_nq Text OK. I'm Detective Sergeant Sean PEARCE. My colleague is: DC HEADLEY Detective Constable Tony HEADLEY. And we are attached to what's called the Serious Crime Directorate, an enquiry team, part of the Metropolitan Police. Ordinarily we investigate murders but on this enquiry that we've been asked to look at is - is an enquiry which emanated'really from the death of Mr MUBAREK at FELTHAM Prison some years ago, which was dealt with 2003(1) "

33 RESTRICTI;D Intervmw of" ROBSON, TONY Form MG15(T)(CONT) Page 2 of 24 by our team. We weren't actually attached to the team at that time. And since then, you'll be aware there's a public enquiry - ROBSON Yeah. into the circumstances of that which is due to start in September, and we've been asked to look at certain aspects of the circumstances that may have surrounded that death and things that maybe have happened in the Prison Service subsequently to that. Could you just introduce yourself for us, please. ROBSON Yeah, I'm Tom ROBSON. I'm a member of the Prison Service but mostly I am concerned with the Prison Officers' Association. I'm a member of the National Executive, working filll time for the Association on secondment from the Prison Service. I'm responsible for the prisons - most of the prisons in LONDON and in KENT. OK. What actually is your role in that in the organisation. What's your title, if you like? ROBSON It's National Executive Committee of the Prison Officers' Association. Right. 2003(1) 33

34 Interviewo_:ROBSON,TONY FormMG15(T)(CONT) Page3 of 24 ROBSON In the Prison Service, which I've not worked in that capacity as a Prison Officer for 6V2 years, I'm a senior officer in the Prison Service. OK, right. Thanks for that. For the record the date is the 22na July /07/2004); the time is 20 past 2 (1420 hours) in the afternoon and we are at EDMONTON Police Station in one of the interview rooms there and we're recording this interview. As I explained, now the procedure: we open a couple of tapes so we can make an accurate record of what we'll talk about. OK. So just so I can get a picture of the National Executive, how many of you are there altogether? ROBSON Right, it's a fairly big team. There are 8 National Executive Committee members which includes a National Chairman. There are then full-time officers who support us, of which there are , which a General Secretary, Deputy General Secretary and a couple of Assistant Secretaries. Obviously we've other support staff as well. OK. ROBSON Other than the full-time officers, which includes the General Secretary and Assistant Secretaries, we're all on secondment under industrial relations procedure from the Prison Service to the POA. Right. 2003(1)

35 REI ;TRICTED Interviewof ROBSON,TONY FormMG15(T)(CONT) Page4 of 24 ROBSON I spend most of my time, as with most of my colleagues really, dealing with Codes of Discipline - which we spend far too much time on really, it's horrendous at the moment. And industrial relations matters, trying to keep the lid on the London Gaols dealing with everything from overcrowding to the type of enquiries that you're associated with. Yeah. ROBSON And the whole spectrum really. And it's just part of the ' structure of the POA. Each establishment itself, which is FELTHAM that we're talking about, WORMWOOD SCRUBBS, has their own committee who work towards... towards you. ROBSON Yeah. ) I see, OK. Well, I'll open this up because essentially what we're talking about here is the - and you may have seen it in various articles in the press - is what has been variously described as 'Gladiator' or 'Coliseum'. Have you been made aware of those sorts of terms? ROBSON Yeah. I'm trying to think about Coliseum a little bit, or Gladiators. I know that there was an article in The Sun., Yeah. '2003(1) _

36 REI ;TRICTED Intelvtewof"ROBSON,TONY FormMG15(T)(CONT) Page 5 of24 ROBSON I've - this is going to sound absolutely crazy, what I'm going to tell you in a minute, I think anyway. OK. ROBSON I'm not certain, absolutely. Coliseum and Gladiators came? up around our table fairly recently and I wasn't absolutely amazed by it, but it came up and I'm not quite sure where the information came from or whether it's true, by the way. Yeah. ROBSON But it then appeared in an article in The Sun newspaper. ] Yes. ROBSON We also, when we talked about it round our Executive table, made a decision that we would report it to the Prison Service, and that's what we did. Right. ROBSON Personally, I've got a bit of a problem with this because I've got a colleague who works for the - he's a mate of mine - who has asked me 2 or 3 times about Coliseum. Right. ROBSON And - I was going to use the word 'allegedly', but that's not right. I apparently told him something about Coliseum... some months ago and I've raeked my brains a couple of (1)

37 Intervmw of ROBSON, TONY Form MG15(T)(CONT) Page 6 of 24 times and strangely enough I've racked my brains a little bit since you rang. Of course, yes. ROBSON There's a Branch Committee at FELTHAM and I need to tell you now, before I go any further, we don't get on. It's one of the branches that I don't particularly get on very well with. OK. ROBSON I don't think they've got much con - well, they've got no confidence or at least the Committee haven't got any confidence about the way I do my particular work. OK. ROBSON Now, the guy who runs the committee as Chairman is a guy called Mr HERRING, Nigel HERRING. Right. ROBSON I haven't particularly got much of a high regard for Mr HERRING. I want to be careful not to do him an injustice here but he, to my mind, he is an idiot! And I don't quite know what the dictionary definition of an idiot is, it might even fit me by what I'm going to tell you in a minute. But he does stupid things and he was involved in what you could describe a sexual harassment case with a - - female officer at FELTHAM (1)

38 Intervaew ot: ROBSON, TONY Form MG15(T)(CONT) Page 7 of 24 Right. ROBSON I don't think it was any big deal but what he did was, he remg up this female who was a member of his Committee - I can't for the life of me remember her name - and she wasn't in. So he made some comments on an answer machine and the lady's daughter listened to the thing and was most upset and all of this. And he was charged under the Code of Discipline mad I got him out of the shit. I mean I went and had a word with the Governor and the Governor was going to take the ultimate sanction of dismissing him if HERRING wouldn't own up. But I got him to own up and have a word with the Governor and smooth it over. OK. ROBSON There's been a couple of things like that. He got into some hot water on an Intemet site and upset some of my colleagues on the NEC and I - he is what I describe as 'an ; idiot'. OK. ROBSON I don't think he takes life very seriously. I'm not so sure he takes his job very seriously. Uh huh. ROBSON But not for the difficult part of what I want to tell you, if... you lake (1)

39 Intervaewof:ROBSON,TONY FormMG15(T)(CONT) Page8 of 24 OK. ROBSON My friend has said to me a couple of times that I've told him something about Coliseum and that Nigel HERRING told me about Coliseum. Right. I ROBSON And I know I must have done because my friend tells me I did, but for the life of me I couldn't swear to it. OK. ROBSON But I have a feeling that either and it would be Mr HERRING; it wouldn't be anyone else - but either he told me that prison officers played a game at FELTHAM of matching two prisoners in a game of what was described as Coliseum or Gladiators. I couldn't swear to which. And that the two prisoners would be put together to see what ' reaction was got. And even, you know, imagining that there was some betting. But I couldn't be certain on that. I think it's complete fiction, by the way, but I have this it just doesn't sound right this at all, but it's a fact. I have a feeling that I would bounce this off my friend cos I bounce nearly everything off him that's unusual. Yeah. ROBSON First of all, in the light of what happened to Zahid _vi'_'ga_k, tu be talking h_ such a vein is absoiute crazy (1)

40 Interviewof."ROBSON,TONY FormMG15(T)(CONT) Page9 of 24 I wouldn't be very confident of a man like that fronting any sort of enquiry for the Prison Officers' Association, or to support his colleagues, when he's talking in that vein. Uh huh. ROBSON I have to now go into what is virtually conjecture, and that is that I've got no doubt something like that did occur and was said to me. I'm even thinking there was a 3_aparty present as well, but I'm not sure. OK. ROBSON I thought it was a bloke being an absolute - I nearly swore on the tape then - but an absolute idiot. I don't believe it for a moment. I don't believe it had anything to do with Zahid MUBAREK. I'd be horrified if I thought that was the case. I'd be horrified ifi thought the staffwere playing a game like that anyway, but when I started to hear it again round the table - I think that's when my mate said to me, "Remember what you told me?" And I've thought about it quite a bit but I really don_t know - You don't have a clear - ROBSON What I'm imagining, and what is clear and that sounds stupid, I know, but that is the fact of the matter. The other thing is that if I felt for a moment that Mr Zahid had been murdered by prison officers by playing a game, whatever they called it, then - then that would be one matter. 2003(1) _I

41 Interviewof"ROBSON,TONY FormMG15(T)(CONT) Page 10of 24 Yeah. ROBSON Dealing with an idiot that shoots his mouth out with a load of rubbish is another and I think that it would be the latter that occurred to me at the time when I spoke to my colleague, if that makes sense. It might not make any sense, but that is the fact of the matter. Can you remember how long ago it was that you had this conversation with Nigel HERRING? ROBSON A good while ago. I couldn't tell you when it would be. When I say 'a while ago', I'm not talking about the time of the MUBAREK murder or anything. No, no, no. ROBSON I'm talking about the last maybe - certainly within twelve months. Maybe 9 months, something like that. Right. ROBSON You see, FELTHAM is not my usual stamping ground. It's not an establishment that I'm usually involved with. OK. ROBSON And I became involved with it again round about 12 months ago. Maybe slightly more than 12 months ago. It wasn't on my patch at the time of the Zahid MUBAREK... murder so I'm not particularly well-versed in it. You 2003(1)

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