Appendix 2: Terms of Reference

Subject to paragraphs 2 and 3 below, the Chairman is to conduct an investigation into the death of Alexander Litvinenko in order to:

(i) ascertain, in accordance with section 5 (1) of the Coroners and Justice Act 2009, who the deceased was; how, when and where he came by his death; and the particulars (if any) required by the Births and Deaths Registration Act 1953 to be registered concerning the death;

(ii) identify, so far as is consistent with section 2 of the Inquiries Act 2005, where responsibility for the death lies; and

¶(iii) make such recommendations as may seem appropriate.

That investigation is to take into account the investigations which have already been conducted by the Assistant Coroner for the Inner North London [Sir Robert Owen].
In the light of the Assistant Coroner's views, expressed in his ruling of 17 May 2013,

(see paragraph 13 of the Judicial Review judgment dated 11 February 2014) that there is no material within the relevant documents to suggest that, at any material time, Alexander Litvinenko was or ought to have been assessed as being at a real and immediate threat to his life, the inquiry will not address the question of whether the UK authorities could or should have taken steps which would have prevented the death.

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Appendix 3: List of Issues

¶A. Background 1. Alexander Litvinenko's life in Russia

a. Personal life b. Career in KGB/FSK/FSB c. Relationship with Boris Berezovsky d. Circumstances of departure from Russia and travel to UK, September – November 2000

Alexander Litvinenko's personal life in UK 3. Alexander Litvinenko's work from November 2000

a. Work for Boris Berezovsky b. Publications c. Work with/for Mitrokhin Commission in Italy d. Work for UK security firms e. Alleged work for UK/Spanish intelligence agencies f. Any other UK/overseas work

Alexander Litvinenko's involvement in political campaigning, media appearances, relationship with dissident/émigré community, 2000 – 2006 5. Actual/threatened/perceived threats to and attacks against Alexander Litvinenko/

¶Boris Berezovsky/Akhmed Zakayev, 2000 – 2007 B. Circumstances of Alexander Litvinenko's death 6. Narrative of Alexander Litvinenko's life/lifestyle during October 2006 7. Alexander Litvinenko's movements/meetings on 1 November and subsequent deteriorating health 8. Medical treatment/hospitalisation/attempts to diagnose 9. Police interviews 10. Immediate circumstances of death C. Post mortem/toxicology evidence 11. Evidence from pathologists/toxicologists

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¶D. Responsibility for death 12. Source of the Po-210 apparently ingested by Alexander Litvinenko

a. Properties/uses of Po-210 b. Scientific analysis of Po-210 samples c. Legitimate trade in/international carriage of Po-210 d. Apparent documentary evidence of consignment of Po-210 at Yaroslavl, August 2006

Andrey Lugovoy and Dmitri Kovtun – backgrounds; movements October/November

2006; public statements since November 2006 a. Andrey Lugovoy background b. Dmitri Kovtun background c. Visit by Andrey Lugovoy and Dmitri Kovtun to London 16 to 18 October 2006 (i) Narrative – travel/movements/purpose of visit/meetings etc d. Visit by Andrey Lugovoy to London 25 to 28 October 2006 (i) Narrative – travel/movements/purpose of visit/meetings etc e. Dmitri Kovtun's visit to Hamburg 28 to 31 October 2006 (i) Narrative – travel/movements/purpose of visit/meetings etc (ii) Evidence of apparent recruitment attempt for poison plan f. Visit by Andrey Lugovoy and Dmitri Kovtun to London 31 October to 3 November 2006 (i) Narrative – travel/movements/purpose of visit/meetings etc g. Andrey Lugovoy – public statements since 2006/polygraph test h. Dmitri Kovtun – public statements since 2006

Traces of Po-210 in London and Hamburg

a. Scientific context/methodology of testing for Po-210 b. Evidence of Po-210 traces (i) Traces in London apparently associated with events 16 to 18 October 2006 (ii) Traces in London apparently associated with events 25 to 28 October 2006 (iii) Traces in Hamburg apparently associated with events 28 to 31 October 2006 (iv) Traces in London apparently associated with events 31 October to 3 November 2006

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¶Appendix 3 | List of Issues 15. Radiation poisoning suffered by Andrey Lugovoy, Dmitri Kovtun and others 16. Alexander Litvinenko's alleged involvement in blackmail 17. Possible involvement of Boris Berezovsky in Alexander Litvinenko's death 18. Possible involvement of Russian state agencies in Alexander Litvinenko's death 19. Possible involvement of UK intelligence agencies in Alexander Litvinenko's death 20. Possible involvement of organised crime/Spanish mafia in Alexander Litvinenko's death 21. The possible involvement of other third parties in Alexander Litvinenko's death, including Mario Scaramella, Chechen groups and others, for example, Alexander Talik

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