Ian MILL
Mr Dennis.
Mr Dennis, in the bundle before you, behind Tab 1, you will find your witness statement. Looking at the final page, can you confirm that this is your signature?
Ron DENNIS
Yes, it is.
Ian MILL
Can you confirm that the evidence is true, to the best of your knowledge and belief?
Ron DENNIS
Yes, I can.
Nigel TOZZI
Mr Dennis, in light of the statement provided by Mr Sutton, I would like to read a declaration by Kimi Raikkonen to you and ask you about it: “I confirm that, during my time at McLaren, between 2002 an 2006, it was routine practice for McLaren to eavesdrop on pits to car radio transmissions of other teams.” Do you agree with that?
Ron DENNIS
During what years?
Nigel TOZZI
Between 2002-2006, when he was your driver.
Ron DENNIS
2002-2006. I am trying to remember the year of encryption. I think that 2002 may be possible.
Nigel TOZZI
In any case, you accept exactly that which Mr Sutton describes Ferrari as doing: eavesdropping on pits to car radio transmissions.
Ron DENNIS
At that point?
Nigel TOZZI
Don’t worry about the dates; I just want you to confirm that this is something that McLaren has done.
Ron DENNIS
It was established practice up and down the pit.
Nigel TOZZI
Exactly. When you carried out your initial investigation, you state that it did not cover the drivers.
Ron DENNIS
That is correct.
Nigel TOZZI
The drivers were aware, of course, that McLaren had been asked to come before the Council, on a charge of being in breach of Article 151 of the Sporting Code.
Ron DENNIS
The drivers?
Nigel TOZZI
Yes, they must have known about that.
Ron DENNIS
They heard about it after 3 July. They must have, from the newspapers.
Nigel TOZZI
Yes, and they knew that the basis for all of those allegations had been that Mike Coughlan was receiving information that belonged to Ferrari.
Ron DENNIS
No. The 3rd July issue focused on a quantity of documents that were, as we all know, obtained by him, copied by his wife, shredded by his wife and burned in the back garden and ultimately, seized on the 3rd of July. Everything that emerged thereafter was focused on the possibility of the material contaminating our company.
Nigel TOZZI
Neither Mr de la Rosa and Mr Alonso came to you at that time saying that there was something you ought to know: that Mike Coughlan had been receiving information from Nigel Stepney.
Ron DENNIS
No, 100% negative. No driver approached me and, in fairness to them, I never approached them.
Nigel TOZZI
Thus, it is established that at least two people on the McLaren team who, in the course of your very thorough investigations, did not come forward with information which I suggest was clearly relevant.
Ron DENNIS
Three people, insofar as Lewis was and is driving the cars. I was trying to establish, through the actions I had unstructured to be taken, whether the drawings or material from those drawings had contaminated the McLaren system. There was no way that I could make the link between drawings
coming into the company and being looked at, or material reputedly floating around. How could I make that link to the drivers? There was no way. It never occurred to me that the drivers could be involved, yet clearly they were.
Nigel TOZZI
When Mr Alonso said to you, after the Hungarian Grand Prix, that he might disclose information to the FIA, unless –
Ron DENNIS
You are wrong in your timing. The exchange between Fernando and I, with his manager present, took place on the Sunday morning of the Hungarian Grand Prix.
Nigel TOZZI
When he came to you, saying that he had information – as you tell us, in the course of a heated discussion – you did not carry out any further investigation to see whether there had been any truth in what he had said.
Ron DENNIS
That is completely out of context.
Nigel TOZZI
Answer the question, then give us the context.
Ron DENNIS
I will not answer the question.
Nigel TOZZI
Very well.
Ron DENNIS
I will give you a detailed account, so that you can put the whole issue in context.
Nigel TOZZI
I am assuming that we have it in your witness statement.
Ron DENNIS
The material placed before the World Council has not been read by all of the World Council members. Therefore, for the Members to understand, I would like to repeat what took place. That is entirely reasonable.
First, the relationship between Fernando and myself is extremely cold. That is an understatement. In Fernando’s mind, there is the firm belief that our policy, whereby each driver receives equal treatment, doe not properly reflect his status as World Champion. He bases this assertion on the fact that his experience and knowledge and what came to him from his former team is such that he should receive an advantage.
In that discussion, he was extremely upset with what had taken place the previous day, but nowhere nearly as upset as I was. He said things that he subsequently and fully retracted. Within the passage of material, he made a specific reference to e-mails from a McLaren engineer. When he made this statement, I said, “Stop”. I went out, brought Mr Whitmarsh him in, and Fernando said everything again, in front of his manager. When he had finished, I turned to Martin Whitmarsh, asking what we should do with this particular part of the conversation. Martin said we should find Max. After Martin and Fernando left, that is exactly what he did. I recounted the entire conversation to Max. I was upset and angry, but mainly upset. Max calmed me down. He said that I should do nothing. I started to calm down. Then, prior to the race, Fernando’s manager came and said that he had lost his temper and completely retracted everything he said. When I phoned Max, Max was understanding and said things to me that are irrelevant here, though I would be more than
comfortable sharing them. He was completely understanding and said that, on the basis of what I told him, if he felt there was any real validity in what Fernando had said, he would contact me prior to taking any action.
I, however, on the basis that this was an engineering matter, I asked Martin whether he thought something was amiss in that area. He told me, “We have been too thorough in talking to the engineers; he cannot have been telling the truth.” We subsequently had a reasonable Grand Prix. Fernando came to me. He had come in 3rd. He apologised for the outburst and I put it down to the heat of the moment, in which he was angry. That is how I took it. Other than following up with Martin, the matter ended there, until 26 days later, when the drivers received a letter. What took place between those times, I do not know. I do not know what circumstances brought that into the public domain.
Nigel TOZZI
That is not quite right. You know what Mr Mosley said in his letter dated 6 September 2007. You know what the explanation is: Mr Alonso apparently showed some information to someone else.
Ron DENNIS
I have not seen anything anywhere indicating who said what to whom. To this day, I do not know how this came to Max’s attention, apart from my telling him. Only Bernie may said that he had seen something and said he would pass it to Max. I do not know what that is. I do know that Bernie
said it was in Spanish, but I do not know how this material came to the knowledge of the FIA. Most certainly, I advised Max of this. I am pretty sure I said to Max that there was reputedly …
Specifically in that conversation with Fernando, Martin said, “You mean, your engineer on the car”. He said, “No, I don’t mean your engineer on the car.
Nigel TOZZI
After matters had calmed down with Mr Alonso and you were once again on speaking terms, you did not ask him then…
Ron DENNIS
We are not on speaking terms, but that does not matter.
Nigel TOZZI
You did not ask him, in a calm and measured way, whether his suggestion that he had e-mails was correct on the basis that, if he did have them, he should have told you about them, rather than keep them up his sleeve. You did not have that conversation, did you?
Ron DENNIS
We have not had any conversations since that point.
Nigel TOZZI
And you did not inquire of Mr de la Rosa, whether he knew?
Ron DENNIS
Why would I talk to drivers, when the conversation with Mr Alonso was subsequently retracted in full, through his manager. Why would I deal with that? And if I were trying to conceal something, would I have called Max?
Nigel TOZZI
Let us put that in context. You started that conversation by saying, “We have never had this conversation”, did you not?
Ron DENNIS
To Max?
Nigel TOZZI
Yes.
Ron DENNIS
I said, “in the strictest confidence”. I do not know that I used the phrase, “We have never had this conversation. I am not disputing that Max’s recollection may be more accurate than mine. The fact
remains that I was speaking to the President of the FIA. Max will tell you that we have a difficult relation. It is not a great relationship, due to various issues in the past years over which we have had differences of opinion. To call him on the telephone and tell him what had taken place clearly indicates that there was absolutely no effort on my part to hide what had happened. There was no such effort at all. It was subsequently retracted and put down to one of our engineers. I had absolute confidence that the information passed to our engineers had not been involved in it. That gave me the confidence that he was not telling the truth. And he retracted it.
Nigel TOZZI
If Alonso had not shown the documents to Mr Ecclestone, and Mr Ecclestone had not alerted Mr Mosley, who then wrote to the drivers, we would not have found out about these e-mails. Is that not so?
Ron DENNIS
The simple fact is that they did not even exist, as far as I was concerned. Nothing existed, because he said that he retracted it, that it did not happen. I phoned Max and said that he had retracted it and calmed down.
Nigel TOZZI
Why is Mr Alonso not here?
Ron DENNIS
Mr Alonso is not here because he does not want to be here. He does not speak to anyone much. He is a remarkable recluse for a driver. He is not here by choice. Moreover, he said he had other things to do by previous arrangement. I cannot force him to come. We asked him to come.
Nigel TOZZI
Would it be fair to say that it would not be as supportive of McLaren’s case as your other witnesses?
Ron DENNIS
I presume that what he has written in his statement is the truth. If our relationship is as it appears to be, why would he make the statement? The statement is the truth. That is what statements are about.
Nigel TOZZI
In your witness statement, Paragraph 3, Sub-paragraph 5, in the context of the investigations carried out, you stated that you offered access to Quest. Ferrari’s experts carried out similar searchers. You say they found nothing. They actually found that the Ferrari dossier – the documents which Coughlan had downloaded onto the CD – had been viewed by him on a computer at McLaren’s premises.
Ron DENNIS
No.
Nigel TOZZI
Are you saying that this did not happen, Mr Dennis?
Ron DENNIS
I cannot exactly remember, but as far as I can recall, there was a reference to material having been looked at, but they did not know what it was. As far as I know, that was consistent with what Coughlan said. Where it happened, nobody knows, because it was on his laptop, which he took back and forth from his home. I therefore have no clue where it happened, nor do I know what he was looking at. It is an assumption that he could have been looking at that material. There was no evidence that he was; that was but a shadow.
Nigel TOZZI
That was a McLaren-owned laptop, was it not?
Ron DENNIS
And it drives home in a McLaren car. Yes, at the end of the day, it was a McLaren computer. But, like many others owned by engineers, it went backwards and forwards. We trust the engineers and believe them to be correct people. But we cannot require them to leave their laptops at the office.
Nigel TOZZI
The computer searches carried out by both your experts and ours did not turn up the e-mail exchanges which Mr de la Rosa and Mr Alonso have now disclosed.
Ron DENNIS
Nor was anything found on the computers that you held on the morning of the 3rd.
Nigel TOZZI
Thus, if there are other e-mail exchanges that have not been disclosed, it is quite likely that they will have been missed by the computer experts as well. Is that not so?
Ron DENNIS
Is that not a double-negative? How can we assume what someone did or did not do? Either it exists or it does not. The forensic nature of those processes, as I understood, was not only very detailed, but could reconstruct most of the material held in a computer. That is why they are
experts. They did reconstruct a great deal of material, as I understand it.
Nigel TOZZI
We can test that in this way. As you told us, on 26 July, when you came before this Council, as far as you were concerned, the e-mails which we have now seen disclosed by Mr de la Rosa and Mr Alonso did not exist.
Ron DENNIS
Can you say that again?
Nigel TOZZI
I am quoting you. You said that, as far as you were concerned, on the 26th of July, when you came before this Council, the e-mails we now have did not exist.
Ron DENNIS
I had absolutely no knowledge of them. How could I? 1 300 people work for our group. How on Earth could I know all about what moves amongst my employees? How do you expect me to know that? I certainly did not know anything about the e-mails moving between our drivers.
Nigel TOZZI
Mr Dennis, I agree with you. This puts into context any categorical assurances, however.
Ron DENNIS
You can only give categorical assurance about knowledge: what you do know, not about what you do not know.
Nigel TOZZI
Thank you, sir.
Max MOSLEY
Do you want to ask Mr Dennis further questions?
Ian MILL
No.
Max MOSLEY
That is all, then, as far as Ron is concerned.
Click here for the full transcript of the 13th of September (in PDF)
Click here for the full transcript of the 26th of July (in PDF)