House of Commons - Public Accounts

Select Committee on Public Accounts Twelfth Report

TWELFTH REPORT

The Committee of Public Accounts has agreed to the following Report:—

ENGLISH HERITAGE: ACCESS TO PROPERTIES

INTRODUCTION AND SUMMARY OF CONCLUSIONS AND RECOMMENDATIONS

1. English Heritage's principal activities include awarding conservation grants towards the cost of the repair or maintenance of ancient and historic properties, the management and conservation of over 400 ancient and historic properties in their direct care, and the provision of advisory and education services. English Heritage received a grant-in-aid of some £104 million from the Department for Culture, Media and Sport (the Department) in 1998-99.[1]

2. English Heritage make grants under the Historic Buildings and Ancient Monuments Act 1953 towards the cost of the repair of buildings of outstanding historical or architectural interest. Grant recipients include public bodies such as local authorities, charitable bodies, private owners and conservation groups such as building preservation trusts. Conditions attached to these grants require recipients to provide public access to the property and, if they sell the property, to repay some or all of the grant. In 1998-99, English Heritage made 114 offers of building grants for secular properties totalling some £7.52 million.[2]

3. On the basis of a report by the Comptroller and Auditor General[3] we examined the Department and English Heritage about the payment of grants, promoting public access to grant-aided properties, and grant recovery.

4. Our main conclusions and recommendations on the issues raised in the report are as follows:

English Heritage must be satisfied that value for money is being achieved from the grants they award to property owners. However, their procedures for establishing how much a grant applicant can be expected to contribute, and for ensuring that grant-aided work is awarded on the basis of competition, have not been followed in a number of cases.

English Heritage require grant recipients to provide public access to their properties. However, they need to ensure that the information they make available to members of the public on the properties that can be visited is accurate and up to date, and to satisfy themselves that the access arrangements are working as they intend. If owners fail to honour the access conditions attached to their grants English Heritage should bring them into line with their obligations, monitor subsequent compliance, and where necessary, recover the grant.

English Heritage need to ensure that grants are recovered when properties are sold. At present they rely on information coming to light rather than systematic action to ensure that they are aware of all relevant property disposals.

5. We also examined English Heritage on the use of their properties for private events, on which we make the following main points:

English Heritage encourage the holding of private events at the properties they manage on the grounds that they generate income and bring other benefits including a higher profile for individual properties and for English Heritage as a whole. English Heritage agreed to the use of one of their properties, Kenwood House, for a private wedding reception, which involved closing the House on the day of the reception and restricting access to the flower garden during an 18-day period. The extent of the restrictions placed on public access in this case are hard to reconcile with English Heritage's policy of minimising disruption to the public when holding private events at their properties.

The then Chairman of English Heritage initiated this use of Kenwood House, a public asset, for an acquaintance on the basis of a voluntary donation of an unspecified amount which the former Chairman eventually paid with his own personal cheque. These arrangements fell below the standards to be expected from public servants.

English Heritage did not disclose to us the full circumstances regarding the payment of the donation for the use of Kenwood House when we first asked. Only in response to our further written enquiries did it emerge that 11 days before appearing before this Committee the Chief Executive had written seeking payment of the donation pointing out that the then forthcoming hearing might draw attention to this matter, that the donation had been paid by the former Chairman of English Heritage, and that the payment had been received only four days before the Committee's hearing. We reiterate the importance of full and helpful answers to the Committee's questions, so that the Committee's enquiries are not frustrated.

6. In more detail, our conclusions and recommendations are as follows:

On paying grants

(i) English Heritage have procedures for assessing the need for grant support, but in five of the 20 cases examined by the National Audit Office involving grants totalling some £532,000 they had not undertaken a formal financial appraisal of the applicant's means. They have now taken steps to ensure such appraisals are undertaken in all appropriate cases and the results recorded (Paragraph 11).

(ii) English Heritage generally require work funded by their grants to be awarded on the basis of competition, and in 40 of the 50 cases examined by the National Audit Office there was evidence from tender evaluation reports that this had been done. In six cases single tender action had been taken on the basis of urgency or because English Heritage considered it to be more cost effective. But in the remaining four cases it was not clear on what basis grant work had been awarded. To be able to demonstrate that they are securing value for money from grants, English Heritage need to have evidence of the basis for the decisions taken (Paragraph 12).

(iii) English Heritage's grant conditions require recipients to ensure that the property is adequately insured while repair works are in progress. English Heritage recommend that insurance cover is maintained once repairs are completed, but this is not a condition of the grant. The substantial sums of public money invested in the repair of historic properties should not be left at risk in this way. We note that in Wales, recipients of grants made by Cadw: Welsh Historic Monuments under the same legislation are required, as a condition of the grant, to insure the property for the 10 years that conditions apply. We recommend that English Heritage require similar protection is in place for the public funds invested in grant-aided properties in England (Paragraph 13).

On promoting public access

(iv) English Heritage recently updated their records of those properties to which members of the public are entitled to gain access. They have made this information available to the public in the form of an access guide posted on their website, and published in a commercial historic house directory (Paragraph 21).

(v) Members of the public, and owners of grant-aided properties, rely on English Heritage publishing reliable information about properties that can be visited. To this end English Heritage must maintain accurate records of the grant conditions they have agreed, when they expire, and the arrangements for visiting individual properties. In compiling their access guide they found that in 135 cases their records were out of date, and access undertakings no longer applied. In following up difficulties encountered by the National Audit Office they found that in some cases the entries in their access guide were inaccurate. To make sure the access guide is accurate they propose to require owners to certify annually that they have given English Heritage correct information (Paragraph 22).

(vi) Although English Heritage require owners of grant-aided properties to provide access to the public, they know little about how the arrangements work in practice. They have no information on the number of visitors to properties, or on the level of entry charges, which could act as a potential barrier to access. They now propose to collect this information as part of the system of annual self-certification by owners, and to make it easier for the public to provide feedback on the response they receive when seeking access (Paragraph 23).

(vii) The National Audit Office were unable to contact some 40 properties on the English Heritage website, and were refused access to 12, in some cases because the website entries were inaccurate. We recommend that English Heritage should also seek direct evidence of how well access arrangements work by carrying out test visits in a sample of cases themselves (Paragraph 24).

On grant recovery

(viii) When grant recipients dispose of their property, English Heritage can recover grants under a clawback clause in the conditions of grant. Although English Heritage have recovered sums where information on disposals of grant-aided properties has come to light, they depend on grant recipients notifying them of their intention to dispose of the property. There is an obvious risk that beneficiaries will be tempted to avoid repayment by failing to notify. In Wales, Cadw: Welsh Historic Monuments intend to secure their right to clawback grants made on any disposal through a legal charge and we recommend that English Heritage take similar steps to protect the public funds invested in grant-aided properties in England (Paragraph 28).

On using English Heritage properties for private functions

(ix) English Heritage agreed to the use of one of their properties, Kenwood House, for a private wedding reception on 9 July 1999. English Heritage's general policy is to set fees for private events at their properties which recover full costs and generate a proper return to the business. In the case of the wedding reception at Kenwood House, mindful of the prestige and publicity the event would bring, English Heritage agreed to the use of the House on the basis of a written contract to recover their costs. However, they did not recover the cost of insurance cover or the cost of time spent by senior officers at headquarters. To avoid the possibility of private events being subsidised by public funds, English Heritage's events business should recover all their costs, including management overheads (Paragraph 38).

(x) English Heritage entered into this arrangement for the use of Kenwood House in the expectation that, in addition to their costs, they would also receive a donation of an unspecified amount. They subsequently received a donation of £5,000 just four days before English Heritage were due to appear before this Committee. The payment was received from the former Chairman of English Heritage on behalf of the ex-King of Greece. English Heritage should put their arrangements for hiring out their properties for private events on a sound footing that does not provide the hirer with discretion over the amount to be paid (Paragraph 39).

THE PAYMENT OF GRANTS

7. English Heritage assess all grant applications against three published criteria: the historic importance of the property; the urgency and nature of the work; and the need for financial help to ensure that public funds are required to get the necessary repairs done. They have an internal panel, the Needs Assessment Panel, to provide advice on the need for grant support. They have arrangements for this advice to be supplemented by a financial appraisal by their Management Accounts Branch of the applicant's means to establish how much the applicant can be expected to contribute.[4]

8. The National Audit Office examined a representative sample of 50 grants for the repair of historic buildings and found that in five out of the 20 cases where a financial appraisal had been required, there was no evidence of an appraisal. The five cases involved grants totalling some £532,000.[5] English Heritage told us that in all 20 cases the Needs Assessment Panel had met and discussed the case and that the Management Accounts Branch had been present at each of these meetings. However, they acknowledged that the Management Accounts Branch had not presented formal written appraisals in five of the cases, as they should have done. They told us that they had now given instructions that in all cases a formal appraisal should be recorded.[6]

9. A key element in securing value for money from grants is to ensure that work is awarded on the basis of competition. English Heritage require grant recipients, as a condition of the grant, to obtain at least three tenders for the proposed work and to provide a tender evaluation report prepared by their professional adviser justifying the selection of the proposed contractor. The National Audit Office confirmed that competitive tendering had been used in 40 of the 50 grants they examined.[7] English Heritage told us that they believed the decision not to seek competitive tenders in six cases had been justified:

in one case by the urgency of emergency repairs needed:

in another case the decision was part of an agreement with a developer that included a provision for profit recovery which English Heritage considered offered better value for money; and

in four cases by the need to retain specialist expertise over a number of phases of the project.[8]

In the remaining four cases involving grants totalling some £240,000 tender evaluation reports had not been provided. English Heritage provided no explanation other than to say that "evidence exists elsewhere that the work had in fact been competitively tendered".[9]

10. English Heritage's standard grant conditions also require recipients to ensure that the property is adequately insured while the works are in progress. English Heritage recommend that insurance cover is maintained once the repairs are completed, but this is not a condition of the grant.[10] We asked English Heritage why, given the substantial sums of public money spent repairing a building, they did not require the property to be insured once the repair was completed as a condition of the grant. They thought it important to insist on insurance while the work was going on, and said that while they advised owners as to the insurance they should take out afterwards, they considered that they must leave owners to take those decisions.[11] The Department thought it highly desirable that the person receiving a grant should adequately insure, but considered that there were a variety of factors including the wide range of repairs that made this a difficult issue.[12] In Wales, recipients of repair grants made by Cadw: Welsh Historic Monuments under the same legislation are required, as a condition of the grant, to ensure that the property is adequately insured for the 10 years that conditions apply and they are required to submit evidence of insurance cover annually.[13]

Conclusions

11. English Heritage have procedures for assessing the need for grant support, but in five of the 20 cases examined by the National Audit Office involving grants totalling some £532,000 they had not undertaken a formal financial appraisal of the applicant's means. They have now taken steps to ensure such appraisals are undertaken in all appropriate cases and the results recorded.

12. English Heritage generally require work funded by their grants to be awarded on the basis of competition, and in 40 of the 50 cases examined by the National Audit Office there was evidence from tender evaluation reports that this had been done. In six cases single tender action had been taken on the basis of urgency or because English Heritage considered it to be more cost effective. But in the remaining four cases it was not clear on what basis grant work had been awarded. To be able to demonstrate that they are securing value for money from grants, English Heritage need to have evidence of the basis for the decisions taken.

13. English Heritage's grant conditions require recipients to ensure that the property is adequately insured while repair works are in progress. English Heritage recommend that insurance cover is maintained once repairs are completed, but this is not a condition of the grant. The substantial sums of public money invested in the repair of historic properties should not be left at risk in this way. We note that in Wales, recipients of grants made by Cadw: Welsh Historic Monuments under the same legislation are required, as a condition of the grant, to insure the property for the 10 years that conditions apply. We recommend that English Heritage require similar protection is in place for the public funds invested in grant-aided properties in England.

PROMOTING PUBLIC ACCESS TO GRANT-AIDED PROPERTIES

14. English Heritage require grant recipients as a condition of their grant to allow a degree of public access to the property, normally for ten years. In 1999 they decided that to improve public information about access arrangements at grant-aided properties they needed to publish an annual access guide. They wrote to the 551 people who, according to their records, had received a grant with conditions requiring them to open to the public. English Heritage subsequently agreed in 89 of these cases that the access condition no longer applied. At the time of the Comptroller and Auditor General's examination they were following-up over 100 cases which had not been resolved. Meanwhile, they included 339 of the properties in their new access guide. English Heritage posted the access guide on their website in August 1999 and in November 1999 published the guide in Hudsons, a commercial historic house directory.[14]

15. We asked English Heritage how their records of applicable access conditions came to contain so many errors, and what they were doing to ensure they had accurate records in the future. They told us that this had been the first time they had ever tried to compile a record of all the grants they had made over the last ten years. They had followed-up all the cases that had been unresolved. As a result 55 properties were now to be added to the website. However, they had discovered that 46 properties were no longer open for valid reasons: for example 35 were outside the ten-year grant period. In five cases English Heritage thought there might be a case for grant recovery on the grounds that owners were not going to be able comply with the access conditions in the future. To ensure the access guide remained accurate, grant owners would in future be required to certify, in an annual survey, that they had given English Heritage accurate details.[15]

16. Until the introduction of their website, English Heritage had not publicised details of how members of the public could register a complaint. Although the website version of the access guide included this information, the version published in Hudsons did not.[16] Responding to our questions, English Heritage also told us that they would be asking customers to give them feedback on the access guide. They acknowledged that it was not good enough simply to have an invitation to give complaints over the web. It was also important that the Hudsons publication invited clients and customers to give feedback on what sort of response they received.[17]

17. The National Audit Office commissioned consultants to obtain first-hand evidence of how access to grant-aided properties works in practice. They sought to contact properties listed on English Heritage's website by letter or telephone to enquire about visiting arrangements. Out of the 317 properties they attempted to contact on the website, they managed to contact 275 (87 per cent) and tried to arrange visits to 80.[18] English Heritage looked into the 12 cases where access was refused and in five of them the owners confirmed that they did give access at times on the website. English Heritage said that as that did not accord with the National Audit Office's findings they would be doing their own checks. In the remaining seven cases the website entries had been inaccurate. They had corrected the entries for two of the cases and they would be removing the remaining five cases from the website. Asked whether they proposed to introduce test visits to identify recipients not complying with grant conditions, English Heritage told us that in future they would be targeting their resources on cases where there appeared to be problems and pursuing them as necessary.[19]

18. Although promoting understanding and enjoyment of the heritage is one of English Heritage's statutory functions, they have little information about the number of visits to grant-aided properties. Similarly, while English Heritage recognise that owners of grant-aided properties may incur costs in allowing public access, and accept charges to offset such costs provided they are not so high as to be a deterrent, they have no record of how many grant-aided properties charge for entry, or how much.[20]

19. We asked the Department what they had done to ensure that English Heritage implemented Government policy of broadening access. They told us told us that they had pursued this through their Funding Agreement with English Heritage, and that the main focus had been on access to properties which English Heritage themselves owned. They had set targets in the three-year Funding Agreement to increase the number of visitors to English Heritage properties from 11.6 million to 12 million a year. However, English Heritage had agreed that in future, as part of the annual self-certification, owners of grant-aided properties were going to have to confirm the visitor arrangements and tell English Heritage how many visitors had come and at what price, if any. As a result, the Department were now going to get regular figures from English Heritage about the number of people visiting grant-aided properties.[21]

20. English Heritage told us that one of the reasons for publishing their access guide was to make it better known that these properties were available to visit. They thought this would have a significant impact on visitor numbers, particularly at the smaller properties. They admitted that they had not monitored whether grant recipients had been overcharging visitors in the past, but they would now start doing so. They would also tell grant recipients in advance that they were going to assess what charges were reasonable.[22]

Conclusions

21. English Heritage recently updated their records of those properties to which members of the public are entitled to gain access. They have made this information available to the public in the form of an access guide posted on their website, and published in a commercial historic house directory.

22. Members of the public, and owners of grant-aided properties, rely on English Heritage publishing reliable information about properties that can be visited. To this end English Heritage must maintain accurate records of the grant conditions they have agreed, when they expire, and the arrangements for visiting individual properties. In compiling their access guide they found that in 135 cases their records were out of date, and access undertakings no longer applied. In following up difficulties encountered by the National Audit Office they found that in some cases the entries in their access guide were inaccurate. To make sure the access guide is accurate they propose to require owners to certify annually that they have given English Heritage correct information.

23. Although English Heritage require owners of grant-aided properties to provide access to the public, they know little about how the arrangements work in practice. They have no information on the number of visitors to properties, or on the level of entry charges, which could act as a potential barrier to access. They now propose to collect this information as part of the system of annual self-certification by owners, and to make it easier for the public to provide feedback on the response they receive when seeking access.

24. The National Audit Office were unable to contact some 40 properties on the English Heritage website, and were refused access to 12, in some cases because the website entries were inaccurate. We recommend that English Heritage should also seek direct evidence of how well access arrangements work by carrying out test visits in a sample of cases themselves.

GRANT RECOVERY

25. The standard conditions English Heritage attach to repair grants require the recipient to inform them immediately in writing if they intend to sell or dispose of their interest in the property so that English Heritage can consider recovering the whole or part of the grant under a clawback clause. The National Audit Office identified five cases of repayment to English Heritage totalling £209,600 over the two years 1997-98 and 1998-99.[23]

26. We asked whether English Heritage had discovered any cases where grant recipients had sold their property without notifying them. English Heritage replied that they had found out themselves about the sale of one of the properties referred to by the National Audit Office and had recovered the grant of £44,000 in full. In the remaining four cases they had been properly notified of the sale.[24]

27. In March 2000 the Audit Committee of the National Assembly for Wales recommended that Cadw: Welsh Historic Monuments should secure its right to clawback grant on any disposal of property on which a maintenance grant has been paid, and that Cadw should explore as a matter of urgency the options open to it for securing stronger legal protection of its interests in these properties.[25] In responding to this recommendation in April 2000, the Cabinet of the National Assembly for Wales noted that Cadw was exploring ways of ensuring that the disposal of a grant-aided property was automatically brought to its attention. As a minimum, Cadw intended to require a legal charge in respect of grants of over £20,000 to private applicants.[26]

Conclusion

28. When grant recipients dispose of their property, English Heritage can recover grants under a clawback clause in the conditions of grant. Although English Heritage have recovered sums where information on disposals of grant-aided properties has come to light, they depend on grant recipients notifying them of their intention to dispose of the property. There is an obvious risk that beneficiaries will be tempted to avoid repayment by failing to notify. In Wales, Cadw: Welsh Historic Monuments intend to secure their right to clawback grants made on any disposal through a legal charge and we recommend that English Heritage take similar steps to protect the public funds invested in grant-aided properties in England.

USING ENGLISH HERITAGE PROPERTIES FOR PRIVATE FUNCTIONS

29. English Heritage are responsible for the management and conservation of over 400 ancient and historic properties in their direct care.[27] We asked about the use of one of their properties, Kenwood House, for a private wedding reception and in the light of the evidence heard we considered it necessary to request further information on this in writing. English Heritage said that they had developed and encouraged such events at their properties on the basis that these could greatly increase the number of visitors to their sites, enhance visitors' enjoyment, generate income and significantly raise the profile of individual properties and of English Heritage as a whole. Many of their 409 historic sites had been used for a wide range of such activities, including weddings and wedding receptions and hiring to private and corporate clients.[28]

30. English Heritage told us that their policy on third party events at their properties was to minimise disruption to the public wherever possible, although there were exceptions. In this particular case, the wedding reception for the daughter of the ex-King of Greece, English Heritage had agreed to close Kenwood House and some half of the estate on the day of the event, 9 July 1999, and to restrict access to the flower garden during an 18 day period of set-up and take-down.[29]

31. English Heritage informed us that the closure of the House and grounds to the public were matters which they had taken very seriously and had been weighed against the benefits of the event. They had taken legal advice about their powers in relation to the House and grounds and had sought the views of their Commission who had decided that they should host the event. English Heritage had judged that the prestigious nature of the event, involving a substantial number of royal guests, would bring very significant international, national and local publicity. Following our interest in the matter they commissioned a valuation of the press coverage which calculated the known media coverage at around £790,000 and potentially at some £2 million across Europe.[30]

32. On the financial arrangements for this event, English Heritage told us that at the time they had no formal schedule of charges or specific arrangements for hiring out Kenwood House. During their first meeting with the event organisers, Party Planners, English Heritage had indicated that an event of the type proposed might cost £25,000, on the basis of their knowledge of the market for corporate and private hospitality. Party Planners had felt that their client would wish to pay any costs as part of a donation to Kenwood House rather than a fee and a note of this meeting had referred to a possible donation of £25,000. English Heritage told us that this sum had been intended to refer to all the money receivable from the hirer.[31]

33. In practice, English Heritage had required Party Planners to sign a written contract to recover all the costs to English Heritage of the event. They told us that they had expected this to be supplemented by an additional donation and that, while they had not known what the value of any donation might be, they had understood that it was likely to be affected by the total cost of the wedding reception. In the event, the cost had turned out to be considerably higher that initially estimated.[32]

34. English Heritage wrote to Party Planners in August 1999 with the final costs for the event of some £34,000 including VAT. This covered direct costs incurred by English Heritage for the wedding reception including additional staff costs. However, English Heritage informed us that it was not their policy to charge a management overhead for central staff and therefore senior officers' time had not been charged for those staff based at headquarters. While they had extended their buildings and public liability insurance policy to cover Kenwood House shortly before the wedding reception, they had also felt that it would be unreasonable to introduce a new charge for this at such a late stage. English Heritage received a payment of £25,500 from Party Planners on 28 October 1999 and the balance of some £8,500 on 4 January 2000.[33]

35. At the hearing we asked English Heritage about the arrangements for payment of the donation. We were told that English Heritage had received a donation of £5,000 very recently and that the delay had arisen because it had taken some time to sort out all the costs and because it had been difficult to press for such a donation.[34] In response to our subsequent written questions English Heritage told us that the then Chairman of English Heritage, Sir Jocelyn Stevens, had pursued the donation orally and had subsequently confirmed in writing that English Heritage would be unable to secure a donation beyond the amount received to cover their costs. The Chief Executive had written to Party Planners on 8 June 2000, 11 days before appearing before this Committee, pointing out that either the production of their Annual Report and Accounts for 1999-2000 or the then forthcoming hearing of this Committee might draw attention to this matter. The donation for £5,000 was received on 15 June 2000, four days before the Committee's hearing, when Sir Jocelyn Stevens paid with his own personal cheque on behalf of the ex-King of Greece.[35]

36. In the light of this information we found it necessary to recall the Accounting Officer to provide an explanation for the responses we received at the first hearing. The Accounting Officer told us that she had been trying to be helpful in responding to questions on a matter which did not arise directly from the Comptroller and Auditor General's report.[36]

37. In response to questions about English Heritage's charging policy we were told that for their overall private events business their policy, in accordance with Treasury guidance, was to recover full costs and generate a proper return. However, the fees for individual events were charged at market rates and reflected the overall benefits the event might bring. The basis on which the English Heritage Commission approved this event was that the costs would be recovered, and that there would be significant prestige and publicity which would bring substantial benefits to the organisation. Although English Heritage had expected a donation, that had been a secondary consideration. Asked if they would be pursuing similar events, we were told that while justified on occasions, they would not want a large number of such events at any of their houses as they would cause more disruption than would be appropriate to English Heritage's overall responsibilities for conservation and public access.[37]

Conclusions

38. English Heritage agreed to the use of one of their properties, Kenwood House, for a private wedding reception on 9 July 1999. English Heritage's general policy is to set fees for private events at their properties which recover full costs and generate a proper return to the business. In the case of the wedding reception at Kenwood House, mindful of the prestige and publicity the event would bring, English Heritage agreed to the use of the House on the basis of a written contract to recover their costs. However, they did not recover the cost of insurance cover or the cost of time spent by senior officers at headquarters. To avoid the possibility of private events being subsidised by public funds, English Heritage's events business should recover all their costs, including management overheads.

39. English Heritage entered into this arrangement for the use of Kenwood House in the expectation that, in addition to their costs, they would also receive a donation of an unspecified amount. They subsequently received a donation of £5,000 just four days before English Heritage were due to appear before this Committee. The payment was received from the former Chairman of English Heritage on behalf of the ex-King of Greece. English Heritage should put their arrangements for hiring out their properties for private events on a sound footing that does not provide the hirer with discretion over the amount to be paid.

1 C&AG's Report HC 457 of Session 1999-2000 Access to properties grant-aided by English Heritage, para 1.2 Back

2 ibid, paras 1.4 and 1.6 Back

3 ibid Back

4 C&AG's Report, paras 3.2-3.3, 3.5 Back

5 ibid, paras 3.1 and 3.6 Back

6 Evidence, Qs 49-50 Back

7 C&AG's Report, paras 3.13-3.14 Back

8 Evidence, Q53 Back

9 C&AG's Report, para 3.14 and Evidence, Appendix 1, p14 Back

10 ibid, para 3.17 Back

11 Evidence, Qs 56-58 Back

12 Evidence, Q65 Back