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UNCORRECTED TRANSCRIPT OF ORAL EVIDENCE To be published as HC 1135-iii House of COMMONS MINUTES OF EVIDENCE TAKEN BEFORE ENVIRONMENTAL AUDIT COMMITTEE (Sub-committee on ENVIRONMENTAL CRIME)
Environmental Crime: Corporate Crime
Thursday 11 November 2004 MR RICHARD HOLMAN and MR GARY SMART Evidence heard in Public Questions 210 - 269
USE OF THE TRANSCRIPT
Oral Evidence Taken before the Environmental Audit Committee (Sub Committee on Environmental Crime) on Thursday 11 November 2004 Members present Mr Peter Ainsworth, in the chair Mr Colin Challen Sue Doughty Paul Flynn ________________ Witnesses: Mr Richard Holman, Company Secretary and Director, and Mr Gary Smart, Manager of The Ministry of Sound Club, examined.
Q210 Chairman: Good morning to you both. Thank you very much for coming along. I appreciate that it is probably a rather unfamiliar venue for you, although you may find that the portcullis strikes something of a chord. This is our final evidence session in an inquiry into corporate environmental crime. You may wonder why you are here. The principal reason is that we are looking, amongst other things, at fly-posting. All of us have seen from time to time Ministry of Sound posters up in places where they probably should not have been, although I have noticed, purely anecdotally, that in the last couple of weeks most of the posters where I normally see them have not been there. I do not know whether that is in any way related to your visit here this morning. Mr Holman: No. It is related to other pressures coming to the surface. Q211 Chairman: Can we just explore the nature of fly-posting and the type of business that you are in? What are the main ways that you communicate with potential customers? Mr Holman: Can I first of all make the point that there are two separate sides to our business, one, the record side, where people like Sony and BMG have been in the frame. We stopped fly-posting for record sales almost entirely some time ago, so we have been using this method of marketing essentially for events. I will ask Gary Smart, who is our club manager, to answer your questions on that side of the business. Mr Smart: Fly-posting is part of the whole network of club promoting. Clubs and sales have got their own sub-culture, their own followers. They know where to see an advert; they know what they looking for; they know what catches their eye. To promote a club night or an event there are only so many things you can do. You can place adverts in magazines, which are somewhat non-specific and a bit hit and miss. You can walk round all the cool shops and the clothes shops and leave bundles of flyers, leaflets, which is allowed, and you can randomly leaflet hand-to-hand in shopping centres in busy areas and club exits. Another key part, which has always been a key part, is fly-posting, whether it be legal or illegal, in places where people stop at traffic lights or will be in queues and will be able to sit there and read them and hopefully what they see appeals to them. New things are coming now - text messaging; you can do an e-flyer, and we do all of these things as well. It is a very important part of getting a very sharp message over very quickly to potential customers. Q212 Chairman: Do you think fly-posting ought to be legalised? Mr Smart: I think it could be legalised or it could be done in a way where there are allocated sites. From our point of view we would like that. We are probably an organisation that could afford to do that. Whether it would stop random individuals doing their one-off parties and putting up posters where and as they see fit, probably not. They would still go about doing that, which is probably the part that makes the place look so untidy. There is a conscientious way of doing it but there are people that really do not care who will just do it anyway. Q213 Chairman: How is it possible to be a conscientious fly-poster? Mr Holman: You have got in there reports where people are sticking things on phone boxes, letter boxes. That is wrong. People should know that. Then there are things like the hoardings round building sites which are temporary and if the posters are in a row they look neat and it does not look that bad in my opinion. Q214 Chairman: What about those telecoms boxes that you see on the pavements? Mr Holman: That looks terrible. It is wrong. It is someone else's property. Old shop fronts - it is wrong. There are certain sites which we have been led to believe by the people that do the fly-posting, framed sites, which I guess used to be owned by the big advertising companies, are legal sites. They have apparently bought these boards and have ten posters in a row. It does not look horrific and it serves a purpose for the events and the club culture that is out there. Q215 Chairman: Can we just come back to something that Mr Holman said, which was that you stopped using fly-posting for the records almost completely. Can you explain the "almost" bit and also why you took that decision? Mr Rowlands: The "almost" bit is because there may still be - I do not think we have done it recently - one or two low-level releases, CD music releases, that are linked to clubbing type events, so they are aimed at the same market as Mr Smart has talked about in relation to club events. Most of our sales now are aimed at the general public, 95 per cent of whom probably would not come to the club at all, and so we use mainstream television advertising to get the message over there because that is the most effective. The reason that we are still using fly-posting in relation to club events is simply because of its efficiency. It reaches the market that we are trying to reach - lots of students, lots of young people. I am sure they do watch television some of the time but they probably do not take note of the adverts and probably do not read newspapers very much. They probably do not plan their lives very far ahead, so fly-posting that they see two or three days before an event is going to be more effective. It has just been the way that club events have been marketed, certainly in our case, for nearly 15 years. Q216 Chairman: But you have stopped doing it in relation to the majority of your record releases for marketing reasons or because of the high profile prosecutions of fly-posting? Mr Rowlands: Not because of pressure from local authorities, but because it was not the most effective way of getting the message across to the public that we were aiming at. Q217 Chairman: Do you arrange for the fly-posting yourselves or do you have an agency that undertakes that for you? Mr Holman: Usually individual promoters. We have our own in-house nights, and obviously if there is a private hire, if someone has hired the club on a Thursday night or a Sunday night for any type of event, they then advertise that event as they see fit. Q218 Chairman: You let them use your logo, do you? Mr Holman: They usually use the logo, yes. I think everyone is aware that it is illegal and even in our contract to private hirers it states quite clearly that they should not do it, and it is something they will do. Q219 Mr Challen: I noticed in parts of the Chairman's statement, for example, that brand licensing had become an important component of your business. In the licence conditions you have just referred to, a contractual arrangement where they are told not to fly-post, or rather, they are told it is illegal, which is not quite the same as saying not to do it, do you have a licence condition that says they should not do it and, if you do have that condition, do you enforce it? Mr Holman: Most of the licensing we do is on the products, hi-fi equipment and so on in Argos and places like that, so this is a fairly small sub-set of the use of the brand. As Mr Smart has said, we will try to prevent people but many of the users of the club are people who take private hires with us, and it may only be one event so it is a bit late to reprimand them afterwards because it has already happened. We probably could take a stronger line and put a double line under that bit of the agreement but it is very difficult to police. Q220 Mr Challen: How many one-off events are there? I do not quite understand the business, you appreciate. Mr Smart: There could be one a week, 52 a year. There are more on some weeks, two or three a week sometimes. Q221 Mr Challen: But if you found that somebody had broken that licence you would not accept them again as a promoter? Would that be the case? Mr Smart: We are quite happy to pass on their details if we receive a letter saying the posters have been seen for the event and it is not our event. We would be quite happy to pass on the details of the person putting them up and they obviously have to react the same way we would when we received that notice. No, we would not stop them from hiring the club. Q222 Chairman: Is fly-posting a reaction to the cost of legitimate advertising? It costs a lot of money, I imagine. Mr Smart: It is not really. We do a lot of legitimate advertising. We are one of the most prolific clubs in the world but we advertise everywhere we want to advertise. Fly-posting is just a very important added extra. Q223 Chairman: Do you know how important? Have you done any market research on who comes and for what reason; how they learned about the event? Mr Smart: No, we have not. Q224 Chairman: You just know? Mr Smart: You talk within the industry and people say, "I saw your poster", "I saw your flyer", "I picked up on your flyers", whatever. If there is a big event on and you have got some activity going on outside it to promote another event that you have got going on, it has got to be as direct marketing as possible. Mr Holman: Fly-posting is only part of the marketing we use. We use e-mails, we use text messages, we use entries in What's On-type magazines. It is part of an armoury. It is not the way we spend all the money and therefore we are not running on a virtually zero marketing budget by using fly-posting. Q225 Chairman: What do you say to the people who feel that fly-posting contributes to environmental degradation in an area? It looks tatty and creates an atmosphere that is tending towards being a bit squalid and therefore tending to encourage rather more serious forms of crime: do you buy that at all? Mr Holman: Yes, we do. Generally we try to meet our obligations. For instance, we have bought our own street cleaning machines and after club nights we go round and make sure that the streets are probably cleaner after the nights when we have had 2,000 people coming out of the club than they were before, with no disrespect to Southwark Council. They do keep the streets very clean. That is an illustration of the way we take our responsibilities. Certainly if we felt that anybody who was fly-posting for us had been behaving in an irresponsible manner, in a way that caused councils to react, we have always responded as rapidly as possible and taken the posters down when we have been told to. We have talked to the fly-posting people if they are clearly going into areas they should not have done. We have cut back on our activity in fly-posting because it has become a sensitive issue with the local authorities. Q226 Chairman: Have you ever used the services of a company called Diabolical Liberties? Mr Smart: No, we have not used them. As far as I am aware it is individual promoters who allocate these posters for companies. London is pretty much split into quarters. If we did a poster run for an event the posters would be split four ways, but one is not Diabolical Liberties, no. Q227 Sue Doughty: I am quite interested in the impact on the business if you are fined. We had Thames and Anglian Water both in here, very different sorts of business, of course. They on the face of it claimed to have a good record on environmental crime but when they get fined it very much hits them in the long run because if somebody does a trawl of their businesses there is something on the record and that is a very big no, so in terms of viability of the business it has had a disproportionate impact because the fines themselves are fairly insignificant compared to their turnover. What do you think is the pressure on you to comply with regulations? Is there any pressure apart from the fact that somebody is going to do you for it? Are there any commercial pressures? Mr Holman: They are not very great. We are not a public company. It is not that Ministry of Sound is not high profile but we do not have quite the sensitivity of large companies with shareholders and there are not any City pressure groups. Clearly, we do not like paying fines and we always try to avoid paying fines if we can. If we are given 48 hours to get the posters down we get them down. Clearly, if we were being hit on the bottom line and our profit was being seriously affected by draconian financial penalties we might react more rapidly, apart from banning the whole thing, which is presumably where we may end up. Q228 Sue Doughty: Is this something to do also with the image of your organisation which has been very sparky and has the appearance of being slightly anarchic? That is your market place? Mr Holman: Yes. Q229 Sue Doughty: So that that market place would almost work directly against something which was very law-abiding, very respectable. That is not where you are in the business world, is it, being respectable? Mr Holman: Precisely. Mr Smart: In a way, although more recently pressure has been stepped up to stop this, we have discussed it with the people we use and have tried to be conscientious as to where the posters go up and we have been informed that the sites they are using now are okay to use. Having said that, we have not received any fines for quite some time. Beforehand it was very random. As you said, there were posters up. Coming under Waterloo Bridge, for example, both sides would be solid posters. Now it is clean, so it is obviously a site that they do not use any more, and we have not received any notices recently. Q230 Sue Doughty: If we were to move towards dedicated advertising areas, and we touched on that earlier, which clubs could use for their posters, would this be an acceptable way forward? Do you think it could work? Would it take the posters off the places we do not want them and put them in other places? If you had your notice boards and young people could go to that place to find out what you were doing, could it work? Mr Smart: In an ideal world it would. You sometimes see these formal sites, not the huge ones that the massive companies buy, but the formal sites in nice framed areas. They do not really work. For example, if the building companies would allow the hoardings to be used to create a framework then you could pay to go on those sites because they are good, visible sites, but if it was too formal it would just be an avenue of information that you would have to cease because it would not have the effect. Mr Holman: I noticed in your report a reference to Leeds where they had drums and we would be interested to know whether that has worked or not. That sort of focused business area where those sorts of posters can be placed would seem to me to need to be very effective. People who come to our events want to know what is going on and we need to find the best channel for reaching them. Q231 Chairman: Certainly Leeds City Council believe it has been very effective because the quid pro quo for putting up the drums allows people to stick their posters all over that but they are very hard on fly-posting elsewhere. Mr Holman: It seems very logical. Q232 Mr Challen: Do you have an environmental policy or a corporate social responsibility policy? These are now getting more and more evident in the world of commerce. Mr Holman: We do not have a written policy, no. There are a number of policies that we are in the process of writing but not specifically those. We are trying to move more towards a full corporate governance regime but at this moment, no, we do not. Q233 Mr Challen: Given that some of your activities, perhaps on a diminishing scale, do involve activities which are illegal, if you like, or at least degrading to the environment, do you not think you ought to have such a policy clearly set out that people can look at and hold you to account on? Mr Holman: That is probably correct. Writing policies is something that does not seem to add much to the business but this sort of issue and also the human resource issue means that we are having to write more policies. I still sometimes question whether a written policy achieves all that much without the full policing behind it. Q234 Mr Challen: In that case do you have somebody with a specific duty within the company to monitor these areas? Mr Holman: No, we do not at the moment. I cannot see us having somebody whose job it is to monitor adherence to any environmental policy. It would not be a full time job unless they had a motor scooter and rode round London looking for illegal fly-posting. Q235 Mr Challen: It would be very hard for your company to assess the impact of fly-posting. Perhaps the only way that you would learn more about it would be when people complained, which is a very negative way of assessing its impact, is it not, or if you have to go to court? Mr Smart: The attention and pressure that has come on is quite recent. I have been in the club for 22 years and fly-posting in every shape and form has always been part of what we do and no doubt what is done everywhere in the world for clubs. The pressure is only coming on now and obviously we are reacting to it. Our first thing was to try and ensure that the companies that do our fly-posting think about what they are doing and wherever we get a warning we make sure we do not do those areas, and the sites they use are in their opinion legal or they own the sites. If that is not the case then obviously that site goes. It is going to get to a stage, obviously, where we just cannot do it and alternatives, if there are any, need to be looked at. The pressure is very recent, is it not? Q236 Mr Challen: It is, I guess. Would there be any value to the company to say, "We are the first in this field to go down this environmental route"? We have been told that a lot of young people are rather fond of environmental causes and whilst we have heard that promoting an anarchic image may have its benefits in one area perhaps this is something you ought to consider. Mr Holman: We will take that up. I think life is moving in that direction and I will suggest that we look at that. Q237 Mr Challen: The Environment Agency said they believed that some companies had set up funds specifically to pay the fines incurred brought about by companies' environmental offences. Do you have such a fund? Mr Holman: We do not. It would be tiny if we did because we have very few fines. As we have said, where we get notices that a poster is offensive we take it down. If the council is clearly concerned and is launching a broader attack then we will reduce or stop fly-posting in that area. They penalties we have paid might have been £500 in a year, if that. Q238 Mr Challen: Do they act as a deterrent, these fines? Mr Holman: In the sense that £500 matters, yes, but it is not material, but they do matter in the sense that we then try to avoid offending again. If we do get warnings from the councils we will stop fly-posting or find out what sites they have been on. Q239 Mr Challen: Is it the approach in your experience of local authorities to come to you first to ask for posters to be removed rather than saying, "We are going to take you to court"? Is there in that sense a co-operative approach from councils to try and remedy the problem, or do they prefer simply to issue a summons? Mr Smart: They try and remedy the problem, definitely, and we are supporting that. They are not taking a particularly aggressive approach. It is just a fine. Mr Holman: Normally it is a stern letter - 48 hours or there will be a bigger penalty or court action. Q240 Mr Challen: I can speak from my own experience of putting up posters during election periods and by-elections are notorious for the amount of posters that go up, but in our case they all have by law to bear an imprint. That could act as a deterrent to people who want to put up posters without saying on whose behalf it is published. It is difficult to conceal on whose behalf your posters will be published but the printer's name has to be on it and the publisher's name has to be on it. Is that something that you think ought to be more widely employed, the idea of putting that information on the bottom of posters so that people can see exactly who is responsible for each stage of that poster's production and distribution? Mr Holman: If there was a penalty regime that was being implemented quite strongly it would be a bigger incentive not to fly-post. As Mr Smart has said, in our case, and no doubt in other such cases, we are used as a venue by other people and it comes back to the point you were making about allowance of the use of our brand and our logo in the area that you are talking about. Q241 Mr Challen: I do not know if you are familiar with the lifestyle provisions in the Proceeds of Crime Act which means that assets of directors of companies, for example, could be seized as well as fines being levied. Do you favour that kind of approach? Do you agree with me that more of a deterrent would be available there? Would you agree that that is an appropriate deterrent for addressing the problem? Mr Holman: As a director of the company I would have to say it is rather a heavy reaction and would only be appropriate in cases of a continuous failure to observe a more measured response. I see it as a fairly extreme penalty that might be necessary to back up anything else. Q242 Chairman: Is not one of the problems that, in your business with your brand, getting into trouble with the law is quite a positive thing? Mr Smart: No. Q243 Chairman: Is it not quite cool to be bad? Mr Holman: No, I do not think that is the image at all. That is certainly not why we fly-post. There may be a slightly fine line between being seen to be slightly underground and cutting edge, but ----- Q244 Chairman: You have a subsidiary called Decadence. Mr Holman: Decadance. Q245 Chairman: Oh, I beg your pardon. Mr Holman: It is not a brand name that we use much. It was somebody's bright idea of a name for a company. No, it is certainly not breaking the law. As a club we have always been very strong in the drugs area, which has been one of the biggest concerns in clubbing, and we helped the Home Office write the new rules for that. It is not part of the Ministry's brief to try to be seen to be sneaky law-breakers. Q246 Paul Flynn: Mr Smart, do you think that the Ministry of Sound fly-posters enhance the beauty of the urban landscape? Mr Smart: Probably not, no. Q247 Paul Flynn: You seem to be suggesting that you are a tasteful law-breaker in that you only allow your fly-posters to go up in a nice orderly way and they are of high aesthetic quality. That is not what you are saying? Mr Smart: I am saying they are in as much as hundreds of banks on the high street are or car showrooms are. They are part of the fabric of society. If they are up and they are not on stupid locations then they add something to society. Q248 Paul Flynn: You are a cheerful, happy law-breaker, you have just told us. You are happy to be a law-breaker? Mr Smart: No. I am under the impression that where we are putting them is allowable by the fact that we are not going to be pulled up or fined. Q249 Paul Flynn: That is not true. You have been fined under the byelaw ----- Mr Smart: Recently? Q250 Paul Flynn: Yes, recently. Mr Smart: We have reacted to those situations. Q251 Paul Flynn: When you were called by Westminster Council to see them to try and ameliorate your behaviour, which people do with law-breakers rather than taking them to court, you failed to attend the meeting. Mr Smart: Who, me? Q252 Paul Flynn: Your organisation did. Ministry of Sound failed to attend when they were called by Westminster Council on 9 December 2002. You were subsequently fined with costs of £352. Mr Smart: I am sorry; I was not aware that we were supposed to attend any meeting. We have always supported the police and the council in things like this if we are asked. Q253 Paul Flynn: But you cheerfully break the law. Mr Holman, I find it fascinating listening to your evidence. I do not want to be unpleasant to you but it is refreshing to hear what Edward Heath described as "the unacceptable face of capitalism". You describe your customers and their lifestyles in sub-moronic terms, you have clear disdain for your own customers and you make it clear that you will happily go on breaking the law and littering the urban landscape as long as it does not hit you in your most erogenous zone, which is your wallet, and nothing else seems to matter. It is all about your profit. If the fines are not big enough you continue to do exactly what you want to do. Is that a fair description of what you said just now? Mr Holman: No, I do not think it is at all. Q254 Paul Flynn: What about on the point that you say you have no environmental policy? Mr Holman: I did not say that. Q255 Paul Flynn: The environment does not matter at all? It does not appear on your landscape at all? Mr Holman: I do not think that was what I was saying. I said we do have an environmental policy. We do not have a written environmental policy but we are very clear that ----- Q256 Paul Flynn: It is a gleam in someone's eye, is it, the environmental policy? You say that no-one is employed doing it. Mr Holman: I have already said that in terms of cleaning up the area round the club, which is one of the most sensitive points of London so the council will be concerned about it, we have made big efforts to ensure that that is dealt with. Mr Smart: We have been doing that for some years. Q257 Paul Flynn: I am another member of this committee who has seen your posters or only knows about you because of your posters. They have suddenly disappeared very recently. The result when they disappeared was not that there was nothing left. The walls that were decorated with these are still a mess. Although it will clear away in time there will still be remnants of them and the place will still look like a slum. What is your view on that? We cannot identify that your posters used to be there. Many of us have passed them on a daily basis coming in to Westminster. Are you happy about that? Your clean-up is just to eliminate your name so you are not blamed for it. Mr Smart: The areas where we are pulled up we do not advertise again and the areas where we want to continue and will continue until such time as we cannot are the areas that we are led to believe are sites that are owned by the poster companies. Q258 Paul Flynn: But the only thing that is going to get across to you or has got across to you is this recent bad publicity about fly-posting. You were not worried about breaking the law. Because it is not an indictable offence you cannot be got at and there it is. Eventually pressure from the public stating what you were doing has got through to you. The other thing that would get through to you would be if the law hit you in your pocket. That is the message that you are giving us with your evidence this morning, is it not? Mr Holman: You used the term "happy law-breakers". Q259 Paul Flynn: You seem very cheerful to me. I do not see any sign of guilt about it. Mr Holman: We have made it clear wherever we have perhaps not focused sufficiently on the full terms of the law but we have tried to a certain extent to work within the law. I doubt if anybody in this room sticks rigidly to every line of every law. Fly-posting, as Mr Smart says, has been going for a long time. We know that it is illegal. There are many other things that happen in the area that are illegal. We have cut back very substantially. The council can come to us at any time; any council can. Q260 Paul Flynn: I am sorry to interrupt you, but is it not true that you used fly-posting when your company was being established to make your name and now you are profitable you do not need to do it and that is the reason you have stopped? Mr Smart: We do need to do it. It is very important. Q261 Paul Flynn: So you will carry on? Mr Smart: If it came to a stage where it was against the law, that we were not using sites that were even ----- Q262 Paul Flynn: It would have to hit you in your own pocket with substantial fines greater than you face now. Mr Smart: We would just have to be informed that what we were doing and where we were doing it was no longer acceptable. Mr Holman: We have said several times that we are now trying to make sure as far as we can that fly-posting is only going up on sites that are legal. Q263 Paul Flynn: Why are you doing that? Mr Holman: Because we want to obey the law. Q264 Paul Flynn: It is nice to see you being repentant and I am sure we welcome that. One would have thought that it was the pressure from councils and others generally that has got through to you, but the real point that you have made, if you look back at your evidence, is the financial matter, that there is no serious risk to your profits from the fine if you are only fined once; it is a footnote in your expenses. Would you say that the reasonable conclusion this committee should receive from your evidence is that a huge increase in the fines and/or you as directors being responsible, with the possibility of losing your property or being indicted yourself for this present activity, would be the effective way to stop fly-posting? Mr Holman: I think you are going to the extreme end of what we said. We have said all morning so far that we will work with councils. We have a job of marketing the business. We have used a method which, I accept, is an environmental crime. For many businesses of our type it has been --- maybe "acceptable" is the wrong word but local councils have not reacted against it. Now it is clear that this is a bigger issue and we should perhaps have addressed this earlier but we are now trying to make sure, which perhaps we should have done before, that we working within the law. We will continue to fly-post in the sense of putting up short-term posters but only, as far as we can possible control it, on legal sites. It is not a financial issue. It is a matter of trying to work within the law and the fact that the law has not been enforced before may have allowed us to behave in a way that now in retrospect we see is not acceptable. Q265 Paul Flynn: So would you like to apologise for the damage you have done? Would you feel a sense of guilt about your activities as the owner of a prolific organisation? Mr Holman: First of all, I am not sure that we are the most prolific, although our logo may appear quite a bit where other people use it. I am not sure that writing apologies is necessary, if somebody wants us to write an apology we will, but that does not seem to address many issues. Q266 Sue Doughty: Can I explore this a little bit further because, in fairness, I think there is quite a lot of information that you have given us about you trying to clean up your act in this. You are in competition with other clubs and businesses which are all doing the same thing, what is your view of the pressure that other businesses are under? In other words, do you have any common approach where you say: "come on guys, it is not in any of our interest, we are going to clear up our act" or will you lose ground if you clean up your act and other people will continue to use these sites that you say are wrong to be there or should not be there? Is this entirely for the councils to deal with through getting to grips with it or is the industry as a whole beginning to recognise this by talking? Mr Smart: I think the industry as a whole is hit by the fact that the amount of posters up is reducing, the amount of sites is reducing and everyone is reacting to the pressure that is on at the moment. We promote events that we feel we need to promote. Without sounding conceited, we do not have any direct competition, so if another club is doing it, it does not bother us. There is no pact for them to stop their posters if we stop ours or anything ridiculous like that, we just advertise an event if we feel the need to. Q267 Sue Doughty: You are not fettered; you are able to veer as appropriate for your own business without worrying about losing ground to another organisation? Mr Smart: Yes. Q268 Chairman: Mr Holman, you said just a while back that you are aware that fly-posting is illegal, but there is a lot of other crime in the area. Are you talking about drug dealing and gun crime? Mr Holman: No. It was probably not a very thought out statement. Q269 Chairman: It does not seem a very strong argument. Mr Holman: No, it is not. I suppose there are things that happen in society - like driving at over thirty miles an hour in a thirty mile zone - which are illegal. People do it from time to time, they know it is illegal but it does not stop them. They will stop when the police stop them. I suppose there is some similarity here, when it is pointed out we should have known. We know that it is illegal, it is a method that has been used by our industry for a long time and the police have not been around. It is clear that it is not acceptable behaviour and we will change it. Chairman: I think that is a very helpful note on which to end. We are very grateful for your time. Thank you very much. |