IV ADMINISTRATION OF SYSTEM
56. The DTI's particular responsibility in strategic
export licensing is for the integrity of the system, as the Minister
responsible emphasised to us in oral evidence.
Other Government departments, principally FCO, MOD and DFID, but
also the intelligence and security agencies and others with technical
expertise, have advice to offer on specific applications: it is
DTI who hold the ring, and issue licences. The system is administered
by the Export Control Organisation, consisting of around 135 staff,
over half of whom are in the Licensing Group devoted to processing
applications and providing technical advice.
The ECO is located in the DTI office in Kingsgate House, Victoria
Street. Members of the Committee paid a most instructive informal
visit there in early November 1998, and were able to see the practicalities
of licence processing.
57. The Scott Report raised the question as to where
in Government responsibility for administration of export licensing
should lie, expressing the view that administration of controls
ran counter to a principal departmental interest of DTI in promoting
exports. In their BMARC Report, our predecessors also recommended
a review of current export licensing responsibilities, in particular
as to which department should have the lead responsibility.
The 1996 Green Paper sought views on this matter.
The responses favoured either an independent authority or body
giving an "extra degree of objectivity" or maintenance
of the status quo but with an enhanced status and closer cooperation
between the various players.
The 1998 White Paper announced the Government's conclusion that
"the licensing authority should remain with the DTI",
a conclusion which has naturally disappointed those seeking change.
58. It is for general convenience that there should
be some form of central point to which all licence applications
can be made, whether covering military or dual - use goods.
There is something to be said for it covering all export licensing,
including works of art and animal products, with advice being
sought in each case from expert departments. Those processing
the application within the Government structure should be able
to have access to the full range of expert advice. Those providing
such advice are only able to do so authoritatively and with a
degree of independence because of their daily involvement with
work other than export licensing. The strength of the present
system lies in its access to, for example, FCO Desk Officers profoundly
familiar with a particular country and MOD technical experts on
a relatively narrow area of technology. No independent authority
could match that, without an absurd waste of resources. There
is also a requirement for Ministerial involvement across departments,
and for one identifiable Minister to take responsibility for decisions
reached. Although we heard that only about 3 per cent of applications
reach Ministers, and that only a handful of those few hundred
lead to active inter - Ministerial discussion
this involvement is the necessary keystone of the system. Licensing
of strategic exports is as much a matter of political judgement
of risk as of technical assessment. It is logical to retain the
central processing unit in that Minister's department.
59. We concur with the conclusion of the White
Paper that the DTI is indeed the appropriate department. We
have detected no excessive championing of intending exporters
by the ECO: such is certainly not the impression given by their
representatives. Transfer to the FCO, or separation from the DTI,
might lead to an excessively negative regime of licensing. There
are some grounds for seeking greater institutional recognition
of the special nature of the ECO within DTI, and closer integration
at a working level with HM Customs and Excise. The priority
at present is however not to jiggle around with allocation of
Ministerial responsibility for the licensing process, but to raise
further its quality and speed.
Work of the ECO
60. It should be recorded at the outset that the
ECO is praised as well as criticised for its performance.
One company responding to the 1998 White Paper stated that most
of the officials were "courteous and helpful but like ourselves
prisoners of a bureaucracy which is cumbersome and overly secretive".
The management of ECO has shown an admirable recognition of the
need for improvement in some areas. It must also be recorded that
applicants do not always do themselves any favours in the way
in which applications are submitted with evidently incomplete
supporting material. The relationship between applicants and a
licensing authority is not and should not be stress - free. The
ECO is engaged in a formal process, ultimately subject to judicial
review. We are encouraged by the prospect of closer liaison
between the ECO and its clients, and of constructive co - operation
in improving current weaknesses.
61. The principal complaint about the licensing
system is the inordinate length of time it can take to get a licence.
Very few are refused: there were 89 refusals of basic Standard
Individual Export Licences (SIELs) between August 1997 and August
This of course understates the real effect of controls, since
some proposed exports will be turned down on the basis of a Form
680 rejection and others will simply not be sought in the first
place. On 24 June 1998, however, there were at least 450 SIELs
which had been awaiting decision for at least 2 months.
The ECO does not at present maintain details of what has been
described as the "tail" of undecided applications, so
that it cannot easily be discovered how many in this waiting list
have been there for many months. The annual rate achieved hovers
around 50 per cent, with a severe recent dip in performance attributable
to uncertainty and the subsequent introduction of tighter controls
in July 1998 following the nuclear tests conducted by India and
Pakistan. Some 15 per cent of circulated applications in October
1998 were for exports to India or Pakistan; staff time devoted
to these apparently had an unquantifiable knock - on effect on
the processing of other licences.
Performance in 1997 was also affected by the need to adapt to
the new July 1997 criteria, leading to a very high rate of referrals
to Ministers of doubtful cases.
The target of 70 per cent achievement of 10 working days (2 weeks)
for non - circulated applications has now been reached. Given
the circumstances, it is perhaps disappointing that any non -
circulated applications should still take more than 2 weeks. The
ECO fails by some distance to meet its own target of processing
within 20 working days 70 per cent of those applications requiring
circulation to other departments: this covers most applications
It is possible to gain a snapshot view of how long licence applications
have been waiting on a specified date: but DTI are "seriously
considering whether we cannot find a means of recording timings
in every case in order to be able to give a better more easily
recoverable, picture of how long licence applications take to
We recommend that vigorous steps be taken to give a rounded
picture of the ECO's performance not only in relation to its own
targets, but showing the full extent and nature of the waiting
- list of applications.
62. We received anecdotal but compelling evidence
from witnesses of the reality behind the figures. Mr Douglas
Garland, Managing Director of RBR International, a leading manufacturer
of personal protection equipment (body armour, helmets, shields
etc) had received only one licence within the 20 day target out
of 9 applications made in the past year.
The Minister has accepted in subsequent evidence to us that a
decision on a May 1997 application to supply helmets to UNHCR
in Afghanistan had indeed taken too long: no decision had been
made by the time the order was cancelled in July 1997.Mr
David Evans, Managing Director of Chemring plc, manufacturers
of military pyrotechnics and other products, told us that, of
140 licences sought since January 1998, 40 per cent had taken
over 50 days and 14 per cent over 100. One, for the export of
stun grenades to Colombia, had been given provisional clearance
through the Form 680 procedure, and a licence was submitted on
29 October 1997; it still awaits a decision, although the order
has now been lost.
From subsequent evidence forwarded, it would seem that after several
months consideration the FCO recommended refusal and that other
departments, including MOD, sought a review of this decision.
Other applications seem to have taken equally long. Some were
for CS gas to understandably sensitive destinations.
Others included an application to export one 30 mm multi - purpose
gun to a laboratory in an EU/NATO country for use in testing;
this took almost a year. An application to export passive air
defence countermeasures to another EU/NATO nation took 6 months.
Mr Evans described the length of time for most of his company's
applications as "unacceptable".
A company responding to the White Paper recorded an average time
of 84 days for applications to be decided, and 3 applications
taking between 18 and 23 months. These were for rifle and mortar
parts to a South Asian country, including a safety device for
the extraction of jammed mortar rounds. We can only hope that
these examples are not typical.
63. The Scott Report proposed that the target time
limits used should be formalised, and specifically that there
should in effect be licensing by default in the absence of a decision
within a prescribed time limit. The 1996 Green Paper sought views
as to whether there should be such limits and if so how they might
The 1998 White Paper turned down the idea of licensing by default,
given the self - evident risk that licences might as a result
be granted "contrary to the UK's international obligations
or the Government's own policy", and set out steps being
taken to improve the speed and efficiency of processing for decision.
The DMA felt that its arguments in favour of licensing by default
had been unduly summarily dismissed.
While that may be the case, we can see little merit in it. It
is clearly important to avoid creating a system which would artificially
encourage a refusal, as a means of reaching a decision. We could
not accept a system which carried with it the inherent risk of
64. The time taken to process applications circulated
to other departments depends to a significant degree on the speed
with which those departments respond. Within MOD, applications
are circulated by the Defence Export Services Secretariat to a
range of expert advisers "in order to produce the agreed
MOD recommendations". Within FCO, the Non - Proliferation
Department is similarly tasked.
There is apparently an "informal" target of 10 working
days for these departments to reach an agreed departmental view.
The extent to which they achieve that target has not hitherto
The DMA and others have the strong impression that it is to consideration
of licences by the FCO that most of the delay can be attributed.
If so that may well be for good reason, such as the need to seek
information and advice from overseas posts on the end - user.
Annex E to the 1997 Guidance for FCO desk officers noted that
10 days is "a target, not a deadline" and that "speed
is not the same as efficiency": it also acknowledged that
"unnecessary delays in processing an ELA can lose the applicant
company money or even a contract. Unexplained delays in the FCO
damage our reputation." It would be pointless for DTI to
take steps to speed up that part of the process for which it bears
direct responsibility only to find that applications linger in
other Whitehall in - trays. We recommend that some analysis
be carried out and published of the reasons for other Government
departments failing to meet a 10 working day target on export
licence applications, and of steps which could be taken to improve
65. In addition to delays, evidence from those doing
business with the ECO has in the past expressed frustration with
various bureaucratic problems
- The absence of reliable information as to the
stage in the system which an individual application has reached,
leading some applicants to believe that their application had
been in effect lost in what one company described as "a black
- The onus being put on the applicant to chase
up progress, rather than the officials concerned taking steps
to hasten matters;
- The inaccessibility for informal discussion or
explanation of those in other departments primarily FCO
and MOD engaged in reviewing applications;
- Officials from different departments, or different
divisions of the same department, seeking additional information
which is unnecessary or which has already been provided, or failing
to understand that which has been provided.
From our visit to the ECO and other sources, we are
satisfied that some steps are being taken to address these matters.
Applicants should be informed what is happening to an application
which will not be decided within the time limit: be offered the
opportunity to make direct representations in response to objections
raised: and be assured of a decision one way or the other within
an agreed further timescale
66. There are relatively few appeals against refusals
of licences: 15 in the most recent 12 - month period.
Following a recommendation in the Scott Report, the 1996 Green
Paper sought views on the creation of a formal appeals procedure
against export licensing decisions.
In response, the 1998 White Paper proposes a statutorily established
formal system of appeals, not however independent as sought by
the DMA and others but comprising senior expert officials.
Where a decision primarily a refusal has been
taken by a Minister, the appeal would also be at Ministerial level.
The right sought by some voluntary bodies for third parties to
be able to appeal against grant of a licence has not been ceded,
to their chagrin: but, as the 1998 White Paper observes, there
is always the possibility of seeking judicial review of export
There should be a time limit for determination of appeals as
there is for giving notice of appeal. It is also our intention
to ensure that appeals are subject to a degree of subsequent parliamentary
scrutiny by select committee.
67. The system of export licensing has always been
subject to judicial review. The Scott Report records the sobering
effect on the DTI of the eventually unsuccessful case brought
in 1983 by Chris International Foods Ltd of a refusal by the Secretary
of State to licence the import of 200 tons of bananas from dollar
It was noted by several respondents to the 1996 Green Paper that
the introduction of formal statutory purposes would make judicial
review a livelier prospect, not only of refusals and grants of
licences, but also of other stages in the process. The 1998 White
Paper notes explicitly that making preliminary advice that no
licence is required (NLR decisions) legally binding would have
the effect of making "licence required" decisions subject
to judicial review.
The proposal to set out some of the procedures in primary or secondary
legislation, or even in statutory guidance, does in our view raise
the spectre of judicial review to an as yet unappreciated degree.
The DMA accepted that there was some prospect of a more litigious
At least one company responding to the 1998 White Paper actively
sought judicial review as an option. We understand that there
has been a recent successful challenge in the German courts to
the refusal by the authorities there of an export licence.
68. Whilst most licences granted are standard individual
licences, much of the volume of trade in controlled goods is carried
on under open licences. There are two types of open licences
- Open Individual Export Licences (OIELs) are specific
to individual exporters, covering multiple shipments of specified
goods to specified destinations: records have to be kept for 3
years (4 years for military list OIELs), open to inspection by
ECO Compliance Officers.
There are currently around 1000 OIELs granted each year, valid
for two years.
- Open General Export Licences (OGELs) remove the
requirement for licencing for specified goods to specified destinations,
requiring only that the exporter register with the ECO its intention
to make use of these derogations. There are 24 DTI OGELs in force;
copies are publicly available.
The system of open licensing grew in the late 1980s
as a means of reducing the administrative burden on frequent exporters
of making large numbers of "repeat" licence applications
for export to standard destinations, and on the ECO in processing
69. The Scott Report noted that goods had been exported
in the 1980s to, for example, Jordan under open licences, and
had subsequently been diverted to Iraq, and concluded that "the
grant of these OIELs left open a gaping hole in the procedural
fences erected for the purpose of policing the Guidelines on defence
- related exports to Iraq....".
Our predecessors' BMARC Report expressed concern at the use of
open licences and recommended a review of their availability in
view of possible diversion.
The system of compliance inspection has been substantially strengthened
since the events on which earlier criticism was based. DTI told
us indeed that "it may become increasingly appropriate to
put more emphasis on self - regulation by making increasing use
of OIELs ....", while accepting that it remained difficult
to identify potential diversionary procurement routes at the moment
of imposing an embargo.
OIELs are not exactly swift to procure. One company wrote that
"we have found that DTI are keen to suggest that we apply
for an Open Individual Export Licence in certain cases but that
these have taken 6 - 12 months to be granted which somewhat nullifies
the benefit of their offer."
Nor does the compliance record suggest that there are many breaches
of the system.
It is obviously necessary to strike a balance between reducing
the burden of unnecessary individual applications and retaining
a degree of detailed control. We counsel caution in moving
too rapidly towards yet greater use of open licences, and Open
Individual Export Licences in particular: and look forward to
detailed reporting of the nature of such licences granted in the
Government's Annual Reports.
70. In its response to our predecessors Report on
Exports to Iraq, the DTI announced that an integrated ECO
- wide computer system was to be in place in 1993. It was in fact
introduced in March 1995.
Our predecessors also noted that MOD had developed its own computer
system incorporating data from ELAs, and that there was no mutual
access between these departments. The Committee recommended that
"the three departments (DTI, FCO, MOD) allow mutual access
to their computerised information relating to export licensing
and that the DTI export licensing database be developed for the
benefit of all three departments."
The Government Reply accepted that there would be merit in more
co - ordinated use of IT and reported that the scope for downloading
licence data from the DTI's ECLIPS system was under consideration.
Such efforts were not however fruitful.
In addition to procedural difficulties, it became apparent in
late 1997 that the ECLIPS database was in some respects seriously
Efforts are now therefore being concentrated on a new project,
ELATE, designed to provide for
- submission of applications in electronic form,
at first by posting a completed diskette, but eventually electronically
- transmission by DTI of this and associated data
to other government departments, at first on diskette and, once
a Government Secure Intranet is established, electronically
- electronic transmission of completed licences
to Customs and Excise, as well as to the applicant.
71. We have seen a hard copy and an electronic on
- screen version of the proposed new application form, which should
in theory save much time and repetitive work, as well as overriding
the need for manual typewriters. Having been trialled it is due
for introduction shortly.
Several of the companies in the trials are pressing for the introduction
of down line transmission rather than postage of a diskette. Some
notes of caution must be sounded. The past track - record does
not give great cause for confidence that there will be a trouble
- free introduction of ELATE. The associated material, notably
end - user certificates provided from abroad and in particular
technical documentation, may not be readily transmissible electronically,
although applicant companies may already have digitalised versions
of technical information. There are also issues of security between
Government and applicant as well as within Government: of validation
of electronic signatures: and of the requirement to keep records
of transactions, not least for purposes of audit and parliamentary
accountability. We are pleased to note the degree of progress
made; the days of ever - thicker files of applications winding
their weary way up and down Whitehall may be drawing to a close.
We recommend vigorous pursuit of the programme of bringing the
export licensing system into this decade before we embark on the
SUMMARY OF RECOMMENDATIONS AND CONCLUSIONS
(a) We note that the Queen's Speech makes no reference
to the Bill. Given that almost 3 years have passed since all parties
accepted the strong recommendation in the Scott Report that there
should be a new legislative framework for strategic export controls,
and that controls are still being operated under a barely refurbished
piece of emergency legislation from 60 years ago, we hope that
time can be found for such largely uncontroversial legislation.
While it may be a nuisance to seek new legislative authority for
other export (and import) controls, it can hardly come as a surprise
to those concerned. We consider that it would in principle be
desirable to repeal the 1939 Act and replace it with wholly new
legislation, rather than seeking to amend it (paragraphs 3 and
Annual Report and parliamentary scrutiny
(b) We hope that the Annual Report will include
details of work underway within the Wassenaar Arrangement, including
efforts to increase the number of participating states, and to
pursue cases where there would seem to have been a failure of
control by participating states. If,
as we envisage, there develops a coherent form of UK parliamentary
scrutiny of strategic exports, it will hopefully be possible to
learn from overseas examples, and to develop a constructive relationship
with similar bodies in other national parliaments (paragraphs
6 and 7).
Parliamentary scrutiny of secondary legislation
(c) The Scott Report devoted considerable space
to criticising the absence of parliamentary scrutiny of the Orders
made under the 1939 Act. The question of parliamentary scrutiny
of Orders made under the 1939 Act and its eventual successor is
therefore of central concern both because of a sorry history of
60 years of failure by Government and Parliament in this regard,
and in the light of the attention devoted to it in the Scott Report.
Parliament must be vigilant to ensure that new arrangements do
not replicate the mistakes of the past. In order to ensure that
significant changes are not slipped through Parliament without
debate, we recommend that (a) drafts of Orders under the new Act
be made available to this Committee in advance of their being
made; and (b) that the Government undertake to find time for a
debate on an Order if at least 6 Members so desire. On this basis,
we consider that the negative procedure for orders laid under
the new legislation will be found acceptable. We recommend that
should Ministers wish to make any further Orders under the 1939
Act prior to the passage of new legislation, they give consideration
to laying the relevant Order before the House (paragraphs 8 to
Parliamentary scrutiny of primary purposes
(d) We welcome the opportunity to be provided
soon for parliamentary scrutiny of the purposes of export controls,
and urge Ministers to go the extra distance to provide an opportunity
for proper examination and debate. We recommend that the principal
list of purposes be set out in the primary legislation: and that
power be given to Ministers to amend that list by secondary legislation
subject to subsequent ratification by Parliament using the modified
affirmative procedure as proposed in the White Paper for agreeing
the original list (paragraph 15).
Parliamentary scrutiny of geographical application
(e) In seeking an appropriate degree of parliamentary
scrutiny of secondary legislation on export controls, the absence
of any equivalent level of scrutiny over the geographical application
of controls comes sharply into focus . There are gaping holes
in the system of parliamentary accountability governing the framework
within which licences are granted, and in particular the geographical
application of controls. Replacement of the 1939 Act will go only
some way towards improving the situation (paragraph 17).
Parliamentary scrutiny of licences
(f) We are content at this stage to continue to
leave individual decisions on export licences to Ministers who
are accountable to Parliament, in accordance with constitutional
conventions. Ministers can however only be properly held to account
for their decisions if Parliament is in possession of the full
facts, and has access on request to detailed casework on decisions
taken by Ministers and those responsible to them. We cannot therefore
accept the bald proposition advanced in the White Paper that there
should be no parliamentary scrutiny of individual applications
after a decision has been taken. What is required
is a system of parliamentary scrutiny which combines the greatest
possible access to the details of decisions taken licences
granted, refused and delayed with safeguards to protect
commercial confidentiality in the interests of individual exporters
and customers legitimate demands for confidentiality. We share
the view expressed that the existence of a robust system of parliamentary
scrutiny can act as a useful prompt to officials and Ministers.
We are confident that such a system can and will be developed
(paragraphs 20 to 24).
National criteria and Code of Conduct
(g) We welcome the publication of criteria
for the grant of arms exports licences hitherto only technically
accessible, providing the necessary yardstick against which to
judge licences granted or refused. Comparison of the new criteria
with their predecessors suggests however that the July 1997 criteria
represent a rather less radical break with past policy than is
sometimes represented to be the case. As before, Ministerial interpretation
of the criteria in difficult cases is the touchstone of their
real significance. We strongly favour the adoption of a
slightly modified set of national criteria so long as it was clear
that it was no more restrictive than the current set in its practical
implementation. We would also welcome confirmation that any proposed
changes to the EU Code of Conduct should be subjected to the new
parliamentary scrutiny procedures for Common Foreign and Security
Policy proposals (paragraphs 28 and 32).
Controls over weapons of mass destruction programmes
(h) The legislation on extension of the
scope of controls over participation in programmes of weapons
of mass destruction could usefully be accompanied by clarification
of the legal position under the Non Proliferation Treaty, and
of the precise scope of the exemptions it is intended to permit
by licence (paragraph 33).
Trafficking and brokering
(i) We welcome the limited proposals on trafficking
and brokering, and recommend that their extension be considered
only once experience has been gained of enforceability. We call
on Ministers to explore further within the EU and the Wassenaar
Arrangement the benefits and potential pitfalls of some multilaterally
agreed form of licensing or registration of arms dealers (paragraphs
35 and 36).
(j) Grave doubts have been expressed as to the
practicality of the proposals relating to transfer of technology
by intangible means and fears raised as to their consequences
if implemented. Given the degree of
controversy raised over the proposals in the White Paper, there
can be no question of the United Kingdom agreeing to an extension
in the EU's dual - use regime, under whatever legal power, until
a consensus has been arrived at on the way forward on controls
of intangible transfer of technology generally. The Government
should consider limiting the proposed extension of licensing requirements
to electronic transfer of documentation to technology related
to weapons of mass destruction (paragraphs 37 to 42).
Review of coverage
(k) The production of a unified list covering
military and dual - use goods under the new Act and the revision
within the EU of the basis for dual - use controls present an
opportunity for review of the present coverage (paragraph 47).
(l)We recommend that the question of controls
on licensed production of arms and dual - use goods be addressed
within the Wassenaar Arrangement (paragraph 48).
End - use controls
(m) We share the sense of disappointment that
there should as yet be nothing to show on the work done on creating
a more effective end-use regime (paragraph 55).
(n) There is something to be said for a central
department to cover all export licensing, including works of art
and animal products, with advice being sought in each case from
expert departments. We concur with
the conclusion of the White Paper that the DTI is indeed the appropriate
department . The priority at present is not to jiggle around with
allocation of Ministerial responsibility for the licensing process,
but to raise further its quality and speed. The priority at present
is not to jiggle around with allocation of Ministerial responsibility
for the licensing process, but to raise further its quality and
speed (paragraphs 58 and 59).
Administration and delays
(o) We are encouraged by the prospect of closer
liaison between the ECO and its clients, and of constructive co-operation
in improving current weaknesses.The principal complaint about
the licensing system is the inordinate length of time it can take
to get a licence. The ECO fails by some distance to meet its own
target of processing within 20 working days 70 per cent of those
applications requiring circulation to other departments. We recommend
that vigorous steps be taken to give a rounded picture of the
ECO's performance not only in relation to its own targets, but
showing the full extent and nature of the waiting - list of applications.
We recommend that some analysis be carried out and published of
the reasons for other Government departments failing to meet a
10 working day target on export licence applications, and of steps
which could be taken to improve performance. Applicants should
be informed what is happening to an application which will not
be decided within the time limit: be offered the opportunity to
make direct representations in response to objections raised:
and be assured of a decision one way or the other within an agreed
further timescale (paragraphs 60 to 65).
(p) There should be a time limit for determination
of appeals as there is for giving notice of appeal. It is also
our intention to ensure that appeals are subject to a degree of
subsequent parliamentary scrutiny by select committee (paragraph
(q) We counsel caution in moving too rapidly towards
yet greater use of open licences, and Open Individual Export Licences
in particular: and look forward to detailed reporting of the nature
of such licences granted in the Government's Annual Reports (paragraph
(r) We are pleased to note the degree of progress
made [in the introduction of electronic document transfer]; the
days of ever - thicker files of applications winding their weary
way up and down Whitehall may be drawing to a close. We recommend
vigorous pursuit of the programme of bringing the export licensing
system into this decade before we embark on the next (paragraph
121 Qq 109 - 110 Back
Ev, p72, Annex C Back
Report, paras 91 - 93 Back
3349, 2.7.1 - 2.7.3 Back
Q29: Ev, p13 Back
3989, 5.3.3 Back
112 - 3 Back
103 - 6 and Ev, Appendix 21: see eg Q38 Back
eg Ev, p32 Back
p65, paras 3.2.7 & 3.2.9 Back
Deb, 24 July 1998, col 741w Back
p151, A4 Back
p65, para 3.2.12: Qq 101,103 Back
p65, 3.2.10 and p74, Annex E Back
p151, A5 Back
136 Q46 Back
Appendix 21 Back
33ff: Ev, Appendix 20 Back
Qq55 - 6: and for use of CS gas in Kenya, Ev, p14, fn15 Back
140 Q40 Back
3349, 2.4.9 - 10 Back
3989, 4.4.1 - 2 Back
& Ev, pp42 - 3 Back
pp66 - 67, paras 4.2.1 & 5.2.3 Back
102, 114 - 5: Appendices 22 etc. Back
show an average of 77 per cent cleared within 10 working days
over the past 12 months: Ev, Appendix 22. FCO have an average
of 70 per cent: Ev, Appendix 23. DFID does not keep detailed
figures but "all applications received are replied to within
10 working days": Ev, Appendix 24 Back
37: Ev, Appendix 25 Back
p67, para 5.3.1 Back
p65, 3.2.9 Back
3349, 2.5.1 - 2.5.3 Back
3989, 4.6.2; Ev, p44 Back
3989, 4.6.1 Back
Report, C l. 50ff Back
3989, 4.2.1 Back
48 - 9: see also Ev, p102, paras 16 - 17 Back
p63, paras 2.3 - 2.4 Back
p67, para 2.5 and p71 Back
87 of 1995 - 96, para 67 Back
p69: p63, para 2.7 Back
p89 (EEV Ltd): also Ev, Appendix 25 Back
p150, A2 Back
Report, para 73 Back
para 75 Back
713 of 1995 - 96, pvii Back
p75, para 3 Back
Deb, 30 October 1997, cols 870 - 1w: ibid, para
details, see Ev, pp75 - 6 Back
3989, 4.4.2:Ev, p , para 6 Back