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INQUIRY INTO THE DEATHS RESULTING FROM THE MANCHESTER ARENA BOMBING ON 22 MAY 2017 ______________________________________________________ OPENING STATEMENT ON BEHALF OF SMG EUROPE HOLDINGS LTD ______________________________________________________ A. Preliminary 1. We wish at the very start of this document to renew SMG’s condolences to the families of the deceased and to the survivors, and also assure the Chairman and everyone else involved with the Inquiry of SMG’s desire to continue to assist the Inquiry in its work. 2. In his first witness statement in these proceedings, James Allen, the General Manager of the Arena, expressed SMG’s sincere sympathies to the families and friends of the 22 people who died in the Attack, and to those who were seriously injured.1 We repeat that expression of sympathy now, in a public manner. 3. In his second statement, 2 James Allen emphasised SMG’s commitment to analysing and acting upon any lessons that can be learned from the terrible events of 22 May 2017. As he said, that process commenced internally immediately after the Attack. That exercise is still ongoing, and SMG regards this Inquiry as an important part of it. SMG has cooperated and will continue to cooperate with this Inquiry not only to respect the process and to help the families obtain the answers that they seek, but also to ensure that the Inquiry’s analysis of what went wrong, and the recommendations that it makes, are as well-informed and as thorough as possible. And if the Inquiry does highlight further changes that SMG can make for the better, it will of course look urgently at implementing those changes, not only at the Arena, but, as appropriate, across all its venues. 4. The Arena is not only physically located at the centre of the City of Manchester. It also occupies a place at the heart of the cultural life of the City, and in the lives of many of those who live and work in Manchester and the North West. SMG values the special regard that so many people have for its flagship venue, and is determined to respect and to honour that regard. It is also true, of course, that the Manchester Arena will now always be linked with the terrible events of the night of 22 May 2017. SMG is committed to working with the families of the deceased and indeed all those affected by the events of that night. The latter category includes SMG’s staff, many of whom were deeply affected by what 1 James Allen first witness statement, paragraph 167 [INQ025577] 2 James Allen second witness statement paragraphs 1.3 and 5.1 [INQ032858] 1 they experienced that night, and all of whom now work in a place that holds painful memories. B. Introduction 5. SMG Europe Holdings Ltd (‘SMG’) is the company that operates the Manchester Arena (‘the Arena’). SMG is a venue and event management company, which specialises in managing Arenas, theatres, stadiums and conference and exhibition centres. SMG currently operates a total of 11arenas and other venues in Europe. The company also works on projects in the Middle East and in Asia. 6. The Arena is the largest of SMG’s arenas. Indeed, with a maximum capacity of 21,000 visitors, it is one of the largest indoor arenas in Europe. The Arena hosts music, comedy, family, sports and other events, and since it opened in 1995, has welcomed over 30 million visitors.3 7. The Arena is a city centre venue, forming part of the Victoria Exchange complex in central Manchester. Its design is highly unusual for a large indoor arena in that it sits directly on top of Manchester Victoria station. 8. In recent years the Arena has hosted well over 100 shows and in excess of 1 million visitors per year. This year, the Arena closed in mid-March as a result of the COVID-19 pandemic and has yet to re-open. 9. It is proposed that the Inquiry will hear oral evidence from four of SMG’s command and control witnesses, who were involved in operations at the Arena in May 2017. a. Miriam Stone has been at the Arena since 2006 and has held the post of Head of Events since 2016. She runs the Events Team (in 2017 comprising her and two others), which (in non-COVID times) is responsible for organising some 130-140 events per year.4 She also took the lead in the period before the Attack in liaising with the Counter Terrorism Security Adviser and in arranging counter-terrorism training. She was the Duty Manager on the night of 22 May 2017. She is due to give oral evidence in both Chapter 7 and Chapter 9. b. James Allen has worked at the Arena since 2003, and has been the General Manager of the Arena since January 2013. As such, he has overall responsibility for the operation of the Arena. He was not on duty on the night of the Attack, but was called in and arrived about half an hour after the explosion. He is due to give oral evidence in Chapter 7 and some of his evidence is to be read in Chapter 9. 3 James Allen first witness statement, paragraph 10-14 [INQ025577] 4 Miriam Stone first witness statement, paragraphs 2-5 [INQ025576] 2 c. Mike Cowley was the SMG Facilities Services Director in May 2017. He was based at the Arena, although his responsibilities at that time also took him to SMG’s other UK venues and SMG’s new developments across Europe, the Middle East and Asia. At the time of the Attack he was in China. He is now employed by SMG China and is based in Hong Kong. He is due to give oral evidence in Chapter 7. d. Paul Johnson has been the Security and Cleaning Supervisor at the Arena since approximately 2005. He was on duty on the night of 22 May 2017 in the role of Fire Safety Officer. He is due to give oral evidence in both Chapter 7 and Chapter 9. 10. Our intention in drafting this opening statement has been to assist the Inquiry, the families and other core participants by identifying what seem to us to be the central issues for the Inquiry to address in relation to Arena security, by outlining the core evidence that SMG witnesses will give in respect of those issues, and by suggesting areas of focus and approach that the Inquiry may wish to adopt. We have avoided descending too far into detail – we are sure that the Inquiry will be more assisted by detail at the stage of closing submissions. 11. We have also endeavoured to comply with the Chairman’s direction to include in this opening statement a narrative of SMG’s performance by reference to the Inquiry’s Terms of Reference, as well as with ILT’s overlapping request that we include our response to the criticisms of SMG that have been made by the Inquiry’s experts. More detail both on the narrative and on the response to criticism can of course be found in the statements that we have served from SMG’s command and control witnesses. 12. All that said, we must immediately add one very important caveat. Our ability to provide an opening statement that is comprehensive has been severely compromised by the fact that some documents, including the security experts’ addendum report and certain witness statements, have only recently been made available to us and other significant documents, including the experts’ final report and other important witness statements, have not yet been disclosed. We say this as a matter of fact, not by way of criticism, but we are sure the Inquiry will appreciate that this has caused us difficulties, not least in taking instructions from our client. For that reason, this document is necessarily incomplete. We will endeavor to fill in the gaps in due course, either by way of an amended written opening statement, or in our oral opening. C. Generic points on the Inquiry’s approach to the evidence 13. We wish to raise at the outset three (connected) points that relate to the way in which the Inquiry should approach the evidence that it will hear and consider. Although these observations arise from our consideration of the Chapter 7 evidence on Arena security, we respectfully submit that they are of general application. 3 The need to focus on causative issues 14. The first of these submissions is that the Inquiry should focus on evidence of matters that are of some causative relevance to the Attack. Put another way, the Inquiry should not spend its time investigating matters that have no real bearing on the deaths of the 22 victims of the bomb on 22 May 2017. Such an approach, we say, is justified on grounds both of pragmatism and of principle. 15. As to pragmatism, the Inquiry has received an enormous volume of documentary and other evidence and intends to call a large number of witnesses to give oral evidence. It will simply not be possible to cover all the issues that arise on the face of the material with all the witnesses, and it is apparent from the relatively short time periods that have been allocated for witnesses’ oral evidence on the Hearing Plan that the Inquiry anticipates limited and focused questioning of witnesses. 16. The Inquiry’s Terms of Reference provide the principled basis (indeed, a requirement) for such a focus. According to the Terms of Reference, the Inquiry’s core purpose is: “To investigate how, and in what circumstances, 22 innocent people came to lose their lives in the attack at the Manchester Arena on 22 May 2017 and to make any such recommendations as may seem appropriate.”5 17.

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