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<p>An independent committee led by the chairs of Go-Ahead Group and Keolis appointed
external lawyers and accountants to conduct an investigation. The Department had input
into the scope of the investigation, which was developed on an iterative basis. In
addition to taking account of the independent committee’s investigation, the Department
raised questions of LSER and of key individuals at LSER, its owning groups and GTR
- and also required the provision of documents and information. The Department has
drawn its own conclusions from all these materials, in particular the contemporaneous
underlying evidence and has set out its rationale for imposing a penalty in the publicly
available penalty notice.</p><p> </p><p>The Department commissioned an external financial
adviser to undertake a review into payments between the Department and a sample of
TOCs, and those TOCs and their affiliates. This review is considering inter alia whether
money has flowed correctly and whether those payments have been correctly accounted
for. This work continues to progress.</p>
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