Select Committee on Public Accounts Seventh Report


SEVENTH REPORT


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

SALE OF PART OF THE UK GOLD RESERVES

INTRODUCTION AND SUMMARY OF CONCLUSIONS AND RECOMMENDATIONS

1. On 7 May 1999 the Treasury announced the Government's intention to sell around 415 tonnes of gold over the subsequent three years, thus reducing the UK's gold reserves from 715 tonnes to about 300 tonnes, and to reinvest the proceeds in foreign currency reserve assets. The programme of sales was to be carried out in a transparent manner, and with a view to obtaining value for money for the taxpayer. The Treasury's objective was to restructure the UK's portfolio of reserve assets by reducing the proportion held in gold and by increasing the proportion held in the foreign currencies, thereby reducing the riskiness of the portfolio.[1]

2. The Treasury has overall responsibility for the sales programme.[2] The Bank of England, as the Treasury's agent, advises on and conducts the sales. Between 6 July 1999 and 12 September 2001, 335 tonnes of gold were sold in fourteen auctions generating £1,999 million in proceeds. The Treasury decided that the sales would take the form of auctions, rather than using existing methods such as the London Gold Fix, a market place for trading which allows gold to be traded twice daily and is regarded internationally as providing the best available indicator of the market price for gold at any one time.[3] The Treasury saw advantage in terms of transparency and fairness in selling by auction directly to a large number of bidders.[4] The auctions were conducted on a uniform price basis: all successful bidders pay the same price, which is determined by the price offered by the lowest successful bid.[5]

3. The proceeds from these auctions have been reinvested in a spread of foreign currency investments - US Dollars (40 per cent), Euros (40 per cent) and Yen (20 per cent) and retained in the reserves. The auctions were conducted in, and the proceeds were received in US Dollars.[6]

4. On the basis of a report by the Comptroller and Auditor General on the auctions that had taken place by May 2000, our predecessors examined whether the Treasury and the Bank of England had achieved value for money and whether there was scope to introduce improvements to the future gold sale programme.[7] We draw three main conclusions:

  • The Treasury are being rigorous in their approach to achieving a reduction in the riskiness of the portfolio in that they are carrying out the sales within a framework of risk assessment and management.

  • As a result of reducing the proportion of gold in the UK's portfolio of reserve assets from 44 per cent to 20 per cent, the Treasury expect to reduce the riskiness of the portfolio by about a quarter. Once the sales programme has been completed, the Treasury should evaluate the outcome to assess how far it has been successful in reducing risk.

  • With the bulk of the sales having taken place, there is no evidence of any significant variation in the value of the portfolio. The Treasury is prepared, however, to lose money in order to lower the risk to the portfolio, and on completion of the programme it will be important for the Treasury to evaluate the financial gain or loss to the portfolio as a result of these sales.

5. Our more specific conclusions and recommendations are as follows:

On achieving value for money

      (i)  In order to secure and maintain the reduction in the riskiness of the reserves portfolio it will be important for the Treasury to continue to monitor the appropriateness of their foreign currency benchmark of 40 per cent in US Dollars, 40 per cent in Euros and 20 per cent in Yen, having regard to the fluctuations in gold prices, exchange rates and interest rates (paragraph 32).

      (ii)  The Treasury decided to sell the gold through auctions in quantities and on dates announced in advance, as part of a process that would be seen as transparent, and so would increase value for money in the long run. There can however be a trade off between transparency and flexibility. For example the Treasury does not announce the reserve price and following the auctions does not disclose information on prices bid; and the Treasury has decided to announce only the date of the next auction and to reduce the amount to be sold in each auction from 25 tonnes to 20 tonnes. In managing such programmes the Treasury should continue to keep these trade offs under review, as its experience develops, in order to maximise the benefits of both transparency and flexibility (paragraph 33).

      (iii)  The first two auctions (6 July 1999 and 21 September 1999) were preceded by a sharp fall in the price of gold, following the announcement of the proposed sales. They were followed by an even steeper increase in the price of gold when the European central banks (including the Bank of England) reached agreement (26 September 1999) on the overall size of their gold sales programme for the subsequent 5 years. It would have been preferable if this agreement could have been concluded and announced before the announcement and start of the UK sales programme (paragraph 34).

      (iv)  Analysis of the prices achieved in the auctions so far indicates that they are in line with the prices that would have been achieved if the London Gold Fix had been used, although interpretation of the figures entails judgement because of the sample size and the uncertainty over the possible impact of the sales on the London Gold Fix price (paragraph 35).

      (v)  The Treasury considers that the outcome of the sales programme in relation to its objectives of reducing the riskiness of the portfolio can only be assessed meaningfully in the medium to long term, because in the meantime temporary fluctuations in asset prices could mask the benefits of risk reduction. The Treasury is also prepared to face a loss as the price of diversifying the portfolio to reduce the risk. At the end of the gold sales programme a reasonable spread of data will be available on the components and weights of the currency benchmark, including the ability to provide protection against shocks to UK macroeconomic policy objectives and minimising market risks (paragraph 36).

      (vi)  We recommend that the Treasury should evaluate the programme at that stage, to determine the extent to which the riskiness of the portfolio has been reduced, and at what price or profit by comparison with not selling the gold, on stated assumptions (paragraph 37).

On changes to the sales programme

      (vii)  Since the sale programme began, the Treasury have carried out three assessments of the options available to sell gold, consulting market participants in the process. We endorse the Treasury's decision, as a result of these reviews, to sell smaller quantities of gold in each auction (paragraph 47).

      (viii)  We also endorse the Treasury's decision to consult market participants as part of their series of reviews of the on-going sales process, because it is important in such programmes for departments to develop as close an understanding as possible of market sentiment and the concerns of other interested parties (paragraph 48).

ACHIEVING VALUE FOR MONEY

Restructuring the reserve asset portfolio to reduce its exposure to risk

6. The Treasury concluded in the late 1990s that the amount of gold held in the reserves represented too great an exposure to an individual asset, particularly as the gold price had been declining for many years, the price was volatile and, unlike foreign currency assets, there was virtually no return on gold holdings. Against a background of increased gold sales by central banks and a downward trend in the market price of gold, the Treasury identified some potential benefits in managing the risks to the reserves portfolio more actively.[8] At the time of the sales announcement in May 1999 715 tonnes of gold, valued at some £4billion, were held in the UK reserves.[9] The Government had not previously sold large quantities of gold from its reserves, only small quantities of gold coins.

7. When asked to clarify the purpose of the policy, the Treasury said that it wanted to diversify the reserves portfolio in the medium-term to reduce the riskiness of the portfolio by decreasing the proportion of the net reserves held in gold from 44 per cent to closer to 20 per cent. It aimed to do this in a way that maximised value for money but transparently, openly and accountably.[10]

8. The Treasury measures the riskiness of the portfolio by a "value at risk" calculation which includes consideration of the maximum loss that might be incurred under certain circumstances. Value at risk is a single summary statistical measure of possible portfolio losses taking into account the probability and magnitude of the likely losses in a given portfolio over a given time horizon.[11]

9. The Treasury illustrated the potential change in the riskiness of the portfolio following the gold sales using a portfolio worth $14 billion, similar to the size of the UK's reserve portfolio, and on the assumption that the non-gold assets were invested in US dollars, euros and yen at a benchmark ratio of 40:40:20. The euro is less volatile than gold, and is more independent of variations in the value of the yen than gold. This key factor underlies the expected improvement in the risk characteristics of the portfolio following the gold sales.[12] The 40:40:20 benchmark ratio is reviewed periodically to ensure that it is still appropriate, given changes in macroeconomic conditions and in currency volatilities and correlations.[13]

10. On the basis of historical data on the movements in the asset prices of euros, yen and gold the Treasury calculated the value at risk—that is the maximum amount that could be expected to be lost over a 10-day horizon, using a 99 per cent confidence level—for two portfolios. The value at risk for a portfolio containing 50 per cent gold is $459 million, compared to $338 million for a portfolio containing 20 per cent gold. The lower gold holding portfolio therefore had a 26 per cent lower value at risk than the portfolio with a higher proportion of gold.[14]

11. Asked whether the UK would pass the UK's gold reserves to the European Central Bank, should the UK join the Euro the Treasury said that members contributed a share of their reserves to the European Central Bank according to a pre-announced formula, although they did retain ownership of them. Fifteen per cent of the reserves contributed are in the form of gold. In the case of the UK, these would be worth about $1 billion. The Treasury confirmed that, in line with its policy of investing the proceeds of the sales in the ratio of 40 per cent in US dollars, 40 per cent in euros and 20 per cent in yen, 40 per cent of the proceeds had been used to purchase euros (about 900 million euros). In terms of the daily flows into and out of the euro this was insignificant. It had not been an attempt to support the euro by the back door.[15]

12. At the conclusion of the sales programme the UK's gold holdings will have been reduced to around 300 tonnes.[16] The Treasury emphasised that gold would remain an important part of the portfolio - about 20 per cent of the net reserves.[17]

Transparency

13. Influenced by its experience in selling bonds, the Government decided to sell the gold in a transparent manner on the basis that transparency should enhance value for money for the taxpayer in the long run by reducing the risk premium priced into bidders' valuations. There was also a growing commitment amongst leading central banks to provide more timely and open disclosure on reserve fund movements.[18]

14. The Treasury said that transparency had enhanced the UK's reputation, especially as a big operator in foreign exchange reserves and that the benefits of operating in an open, transparent and predictable fashion could spill over into other areas. For example the UK could borrow money from the markets more cheaply than any other country - with the possible exception of Japan and Switzerland. It was important to the UK's reputation to be seen to be selling gold in a transparent way.[19]

15. The London Gold Fix is recognised internationally as providing the best available indicator of the market price for gold at any one time. References to market prices for gold are therefore references to prices achieved in the London Gold Fix.[20] The price of gold fell sharply—by about 10 per cent—after the UK's May 1999 announcement to sell gold was made, reaching a 20 year low of $252 per ounce shortly after the first UK gold auction. The price increased sharply to $325.50 an ounce in October 1999 following an agreement by European central banks to limit gold sales over the next five years. Since then the price of gold has mainly remained under $300 an ounce.[21]

16. The impact on the price of gold following other international gold sales has generally been less than the impact of the UK's announcement. In the case of the Swiss programme of sales, which is substantially larger than the UK's, the price impact had been less, mainly because that country went through a more protracted process including a referendum to approve the sale. The Treasury explained that it had expected there to be a fall in the price following its announcement, although it had not been clear by how much. The Bank of England said that a factor in the softening of the gold price after the UK's announcement was knowledge that the Swiss also intended selling gold.[22]

17. Asked about the sharpness of the fall in the gold price after the UK announcement compared to the relatively small amounts at stake, the Treasury said in evidence that there would have been an even greater price response had it tried to sell covertly in the market, rather than announcing the sales. IMF guidelines on disclosure of reserve holdings meant that sales would have become quickly apparent and raised concern that all the UK gold reserves were going to be sold.[23]

18. Other countries have disclosed less information about their gold sales. Some countries have sold discreetly and without prior announcement of the decision to sell gold. Many central banks do not publish the gold prices achieved in individual sales and are often unwilling to disclose such information.[24] The Treasury itself has a reserve price for each auction below which it will not sell, but does not announce that price because it would set a floor to the auction price. After the auction has taken place, not information is given on prices bid in the auction to avoid facilitating collusion between bidders.[25]

19. The Treasury said that, in its view, there was no cost in acting transparently as best value was achieved by opening up the sales to the maximum number of buyers as had been done in the auctions. Comparison of the prices achieved in the auctions with the best available benchmark, the London Gold Fix, demonstrated that gold was sold transparently without losing value.[26]

Flexibility

20. The Treasury considered that greater flexibility could not be expected to lead to better revenues than current market expectations. The market viewed a more flexible approach as an option that would only be exercised if it benefited the seller. The Treasury had to trade off the market's desire for predictability against the advantages of a degree of flexibility. It accepted that it was not easy to judge how much could be gained by predictability. It had moved towards being more flexible by only announcing one auction in advance rather than two as it had done at the start of the sales programme.[27]

21. Asked whether announcing the date of the second auction (21 September 1999) so far in advance had left it unable to take advantage of the significant strengthening of the gold price when the European central banks' agreement was announced (26 September 1999), the Treasury said that cancelling the second auction would not have been an appropriate response. It would not have been right for the UK to be opportunistic and rely on insider information. Delay or cancellation would have raised questions in the market and might have put the European central banks' agreement at risk. As to whether speculation about delaying the auction would have resulted in higher prices, the Treasury said that essentially it had been concerned to preserve its reputation for future sales. It would also have been difficult to know what impact the European central banks' agreement would have on the gold price.[28]

22. A review by the Bank of England found some support from market participants for smaller, more frequent auctions. Many favoured the use of the London Gold Fix which they saw as a logical extension of smaller more frequent sales.[29] In response to a question on whether use of the London Gold Fix would have had advantages over the auctions because it would not be such a focus for adverse sentiment, the Treasury and the Bank of England agreed that the London Gold Fix was a viable alternative to auctions, and that the market preference was for smaller amounts to be sold each day in the Gold Fix. They agreed that the London Gold Fix was indirectly available to all market participants and that it would be feasible for the Government to be transparent about sales it made using the London Gold Fix by announcing how much it intended to sell and over what period.[30]

23. The Treasury and the Bank of England confirmed that they valued the greater transparency of auctions including the ability to release the bid cover ratio, which showed the extent to which the volume of gold bid exceeded the volume offered. Witnesses also confirmed that they were concerned about fairness in the sense of the sales being open to all participants on the same terms. Auctions had the advantage of opening up the process directly to a large number of potential buyers, who would otherwise have to ask a London Gold Fix member to bid on their behalf; but some of the non-members would be competing banks who would not necessarily want to disclose their orders to competitors. In addition London Gold Fix members charged a commission to outsiders on orders they execute.[31]

The prices achieved

24. Between July 1999 and September 2001 335 tonnes of gold were sold in 14 auctions every other month. Bids at the auctions could be submitted by the members of the London Bullion Market Association, by central banks and by other international monetary institutions holding gold accounts at the Bank of England.

25. The average price achieved was $273.01 per ounce. That price was 37 cents above the average of the London Gold Fix prices on the day of the auctions. It was equivalent to less than one per cent below the average of the London Gold Fix price of $274.86 per ounce over the period of the auctions. Interpretation of these figures is a matter of judgement since none of them is statistically significant, given the small size of the sample. The potential impact on the London Gold Fix price of the sales cannot be gauged and would depend on whether the auctions attracted more demand for gold than would be achieved in the London Gold Fix. The Treasury expected to achieve the average price of gold as measured by the London Gold Fix price over the course of the whole programme.

26. The Treasury had analysed the apparent propensity of the market price to rise sharply shortly after the auctions. It had analysed price movements (in US$ and percentage terms) for each of the ten auctions at 15, 10, 5 and 1 day(s) before the auctions and could find no consistent pattern in price movements up to or following auctions. Prices have tended to fall slightly before the auctions, but they have also tended to fall after the auctions.[32] Figure 1 shows the variations in the London Gold Fix prices during the period of the fourteen auctions.


Investment of gold sale proceeds

27. The proceeds of the gold sales were received in US dollars and were re-invested in foreign currency interest bearing assets at a ratio of 40 per cent US dollars, 40 per cent Euros and 20 per cent Yen, a formula which is consistent with the composition of the net currency reserves. The return on gold is around half of one per cent compared to about 6 per cent for interest-bearing foreign currency assets. By November 2000 that reinvestment had generated an additional return to the taxpayer of US $52 million, or £35.5 million.[33]

28. The Treasury said, in relation to how it had determined the composition of the foreign exchange portfolio, that it had determined the portfolio ratio by considering what it wanted the foreign currencies for, the proportions of UK trade with different parts of the world, and the ease with which these currencies could be used for intervention purposes. It aimed to keep a small number of highly liquid currencies that roughly reflected the UK's trade patterns. The Treasury took the view that, at times, the 40:40:20 split would work better than others, but that over the medium term it gave a reasonable balance.[34]

29. Asked about the impact of any changes in prime factors, such as the UK's trade weighting, the Treasury provided details of the factors that it took into account when making a judgement on the balance of assets to be held (Figure 2). It periodically reviewed the appropriateness of these and also discussed the long-term strategic issues relating to the overall foreign exchange account at six monthly meetings with the Bank of England.[35]

Figure 2: The components and weights of the net reserves currency benchmark
BenchmarksDeterminants of the benchmark
InterventionTo be able to intervene in the foreign exchange markets. This points to investing in relatively liquid assets—i.e. US, Europe and Japanese currencies.
  Most readily usable for intervention—suggests holding larger proportion of dollars and euros.
Macro economic factorsRequired to finance outflows of trade and capital account without selling sterling in the event of a period of financial instability.
  To provide protection against shocks to the UK macroeconomic policy objectives—suggests a case of investing in yen as a currency which is less likely to be weak at the same time as the other two currencies.
Risk and returnMinimising the market risks on investment grounds—suggests holding dollars (30% to 50%) euros (40% to 70%) and yen (0% to 10%).
  Analysis of historic returns on currencies. Recent data suggest that the dollar has been the highest yielding.

Source: Evidence, Appendix 1— determination of the composition of the UK's net foreign currency reserves

Impact of the gold sales programme on the value of the portfolio

30. The impact of the gold sales programme on the value of the portfolio can be calculated by comparing the value that will arise as a result of selling the UK gold with the portfolio that would have existed had the sales not taken place. The Treasury considered that a meaningful assessment of the financial benefits could only be undertaken over the medium to long-term, and that in the short term wide fluctuations in the gold price, exchange rates and short-term interest rates could significantly impact on the results.[36]

31. At 18 December 2000 there was a small gain of US $34 million (£23.1 million) in the value of the portfolio taking into account the interest gained from the foreign securities bought with the proceeds of the gold sales. By 23 January 2001, after the tenth auction had taken place, this gain had increased to around US $100 million (£68.1 million).[37] The Treasury said that it was nevertheless prepared to face up to the prospect of losing money to achieve its main aim of lowering the risk of the portfolio.[38]

Conclusions

32. In order to secure and maintain the reduction in the riskiness of the reserves portfolio it will be important for the Treasury to continue to monitor the appropriateness of their foreign currency benchmark of 40 per cent in US Dollars, 40 per cent in Euros and 20 per cent in Yen, having regard to the fluctuations in gold prices, exchange rates and interest rates.

33. The Treasury decided to sell the gold through auctions in quantities and on dates announced in advance, as part of a process that would be seen as transparent, and so would increase value for money in the long run. There can however be a trade off between transparency and flexibility. For example the Treasury does not announce the reserve price and following the auctions does not disclose information on prices bid; and the Treasury has decided to announce only the date of the next auction and to reduce the amount to be sold in each auction from 25 tonnes to 20 tonnes. In managing such programmes the Treasury should continue to keep these trade offs under review, as its experience develops, in order to maximise the benefits of both transparency and flexibility.

34. The first two auctions (6 July 1999 and 21 September 1999) were preceded by a sharp fall in the price of gold, following the announcement of the proposed sales. They were followed by an even steeper increase in the price of gold when the European central banks (including the Bank of England) reached agreement (26 September 1999) on the overall size of their gold sales programme for the subsequent 5 years. It would have been preferable if this agreement could have been concluded and announced before the announcement and start of the UK sales programme.

35. Analysis of the prices achieved in the auctions so far indicates that they are in line with the prices that would have been achieved if the London Gold Fix had been used, although interpretation of the figures entails judgement because of the sample size and the uncertainty over the possible impact of the sales on the London Gold Fix price.

36. The Treasury considers that the outcome of the sales programme in relation to its objectives of reducing the riskiness of the portfolio can only be assessed meaningfully in the medium to long term, because in the meantime temporary fluctuations in asset prices could mask the benefits of risk reduction. The Treasury is also prepared to face a loss as the price of diversifying the portfolio to reduce the risk. At the end of the gold sales programme a reasonable spread of data will be available on the components and weights of the currency benchmark, including the ability to provide protection against shocks to UK macroeconomic policy objectives and minimising market risks.

37. We recommend that the Treasury should evaluate the programme at that stage, to determine the extent to which the riskiness of the portfolio has been reduced, and at what price or profit by comparison with not selling the gold, on stated assumptions.

CHANGES TO THE SALES PROGRAMME

38. The Treasury has undertaken three formal assessments of the options available to sell gold: the first, three months before the first auction; the second, in February 2000 and the third in the first quarter of 2001. In undertaking these assessments the Treasury received technical advice from the Bank of England as its agent and looked at the experience of gold sales in other countries.

39. The Treasury accepted that there could be ways in which the programme could be improved which was why it and the Bank of England were in the process of reviewing it again, taking into account the issues raised by the National Audit Office. The review examined all aspects of the gold sale programme including the alternative methods of selling gold, particularly use of the London Gold Fix, the possibility of retaining more flexibility in selling gold, the information provided to the gold market and the management of the sales programme.[39] It also took account of the experience of the auctions that had taken place and involved discussions between the Bank of England and market participants, analysts and other interested parties.

40. As a result of the review, and following the hearing with our predecessors, the Treasury announced in March 2001 that the gold sales to take place in 2001-02 would consist of six auctions and, that each auction would be smaller - 20 tonnes rather than the 25 tonnes previously sold, and that sales would continue to be held bi-monthly using the uniform price auction format.[40] These sales would complete the UK's gold sale programme.

41. The market participants canvassed by the Bank of England, as part of the review of the auction process, were roughly evenly split between continuing with bi-monthly auction, moving to more frequent smaller auctions and using the London Gold Fix. The review concluded that auctions continued to be the most fair and transparent form of sales, while, in value for money terms, auctions and the London Gold Fix were likely to deliver broadly similar outcomes.[41]

42. The National Audit Office identified some of the key forms of flexibility that could be introduced into the process and the potential implications of these. They included deciding on the amount to be sold only shortly before the auction, announcing a range for the amount to be sold or publishing a supply schedule in advance showing how much the Treasury was prepared to sell at different prices. The benefits of these forms of flexibility relate mainly to stabilising price volatility following the auction. They would not necessarily lead to a higher expected return.[42]

43. The Treasury review of the auction process found little support from market participants for announcing a range for the amount to be sold and/or deciding the amount sold when allocating the bids. There was more support for more frequent sales and selling into periods of temporary demand. A large number of market participants were, however, against all forms of flexibility with some feeling that opportunistic sales would lead to a more jittery market and potentially worse prices in the sales. Some thought that flexibility would be inconsistent with a transparent approach and that the reputational risk was not worth taking. In the light of these views and the Bank of England and Treasury's own views about the potential implications of retaining flexibility in the sale process, the Treasury decided to continue selling gold on the basis of fixed amounts announced in advance.[43]

44. There was some support in the market for smaller auctions. Market analysts advised that, since the programme had been announced, volumes traded had become lower, making 25 tonnes a relatively larger amount to absorb. The Treasury had regard to that fact in announcing in March 2001 that the individual auctions would be of 20 tonnes in future.[44]

45. After each auction the Treasury disclose to the market details of the price achieved, the total proceeds and the bid-cover ratio. While the majority of the market was satisfied with the level of information provided, the usefulness of the bid cover ratio had been questioned by some market participants. There had also been a call for more information on the bids received.

46. The Treasury review found little support among market participants for the publication of more post-auction information. Some considered that other measures would be open to manipulation, while publishing more information was seen as potentially risky because it might be over-analysed and viewed as negative by the market. The Treasury also considered that publishing more detail of bids could increase the risk of collusion between market participants. It decided to continue publishing the bid cover ratio and not to increase the disclosure of post-auction information.[45]

Conclusions

47. Since the sale programme began, the Treasury have carried out three assessments of the options available to sell gold, consulting market participants in the process. We endorse the Treasury's decision, as a result of these reviews, to sell smaller quantities of gold in each auction.

48. We also endorse the Treasury's decision to consult market participants as part of their series of reviews of the on-going sales process, because it is important in such programmes for departments to develop as close an understanding as possible of market sentiment and the concerns of other interested parties.


1  C&AG's Report, HC 86 Session 2000-2001, The Sale of Part of the UK Gold Reserves, paras 1-2, 12 Back

2  ibid, para 2.5 Back

3  ibid, para 4  Back

4  Q116 Back

5  C&AG's Report, para 2.9 Back

6  ibid, paras 2.4, 2.22 Back

7  C&AG's Report, HC 86 Session 2000-2001 Back

8  C&AG's Report, paras 2.2-2.3 Back

9  ibid, para 1.6 Back

10  Qs 2, 9, 30 Back

11  Evidence, Appendix 1, pp 18-29 Back

12  ibid, pp 26-29, Value at risk: A worked example Back

13  ibid, pp 18-21, Determination of the composition of the UK's net foreign currency reserves Back

14  Evidence, Appendix 1, pp 26-29, Value at risk: A worked example Back

15  Qs 16-17, 24-29 Back

16  Q55 Back

17  Q30  Back

18  C&AG's Report, paras 13, 3.4-3.5 Back

19  Q128 Back

20  C&AG's Report, para 3.10 Back

21  ibid, paras 2.7-2.8; Q96 Back

22  C&AG's Report, para 2.8 and Appendix 4, Qs 96-97, 140 Back

23  Qs 4, 140 Back

24  C&AG's Report, para 2.17 Back

25  Qs 45-47 Back

26  Qs 5, 11, 38, 116 Back

27  Qs 11, 37 Back

28  Qs 6, 97, 99-100, 103 Back

29  C&AG's Report, para 4.3 Back

30  Qs 7-8, 13 Back

31  Qs 7, 13-14, 88-92 Back

32  Q133 and Evidence, Appendix 1, pp 18-29 Back

33  C&AG's Report, paras 2.22, 2.24 and Qs 65, 125 Back

34  Qs 51, 71, 114, 136 Back

35  Evidence, Appendix 1, pp 18-29 Back

36  C&AG's Report, paras 2.22-2.23, 2.26 Back

37  ibid, para 2.26 and Q36 Back

38  Q9 Back

39  C&AG's Report, para 3.17 Back

40  Qs 15, 34 Back

41  Evidence, Appendix 2, pp 30-31 Back

42  ibid Back

43  ibid Back

44  C&AG's Report, paras 4.6-4.7 Back

45  ibid, paras 4.3, 4.20, and Evidence, Appendix 2, pp 30-31 Back


 
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