Select Committee on Work and Pensions Fourth Report


344. The State Pension age for women is already due to rise from 60 to 65 between 2010 and 2020. In the White Paper the Government proposes a rise from 65 to 66 for men and women over a two-year period from 2024, a rise from 66 to 67 over a two-year period from 2034 and a rise from 67 to 68 over a two-year period from 2044. [432]

345. The Pensions Commission had concluded that "State Pension Ages will in the long-term need to rise broadly with increases in life expectancy so that each generation spends a roughly similar proportion of adult life contributing to and receiving a state pension."[433] In its modelling it "assumed that the SPA rises after 2020, reaching 66 in 2030, 67 in 2040 and 68 in 2050."

346. The impact of the White Paper reform on people of different ages is set out below: Table 6: Impact of White Paper on State Pension Age

Source: White Paper, p 147

347. The Secretary of State explained that similar measures were being taken in "most other developed countries"[434], adding:[435]

    "I am absolutely convinced that it is inevitable and absolutely essential that the State Pension Age increases in the way that we have suggested in the White Paper, not only because that is fair between the generations because it is simply just matching the increase in longevity."

Finding consensus?

348. There is a good news story to be told: people are living longer. Richard Willets, from the Actuarial Profession, told us:[436]

    "at the moment mortality rates for people aged 65-plus are improving at a far faster rate than they have ever done in the past. In fact, if you take men aged in their 60s and 70s, the pace of change is about ten times as rapid as it was during the first seven decades of the 20th century, so we have seen a real step up in the pace of improvement. That has been driven primarily by huge reductions in heart disease mortality."

349. However, the raising of the State Pension Age to reflect this hoped for change is one of the most controversial aspects of pension reform and an area in which it is particularly difficult to reach consensus. The Government's proposals were greeted with headlines such as "Work 3 more years, get £3 pension rise"[437] and "Work till 68 for £3 a week; State Pension Shock for Millions."[438] It is a shame that this line was taken on these important proposals, and that a more balanced view was not presented.

350. At the beginning of the Government's National Pensions Day only ?39% of those present agreed with the idea of a gradual increase in the State Pension Age (though this increased to 55% at the end of the day, once the reasons for the change had been put forward).[439] The National Pensioners' Convention told us that:[440]

    "there is no public support for this, the majority of people being hostile to the idea of being forced to work longer to fund their retirement […] today's poorer workers would end up working longer, drawing their pension for a shorter time and dying sooner."

351. The Government itself considered, but rejected, proposals to increase the State Pension Age in its 2002 Green Paper, Simplicity, security and choice: working and saving in retirement.[441] It argued at the time that:

    "An increase in State Pension Age would also reduce long-term public expenditure. However, it would disproportionately affect lower-income people who rely more on state benefits in retirement. The same people tend also to have lower life expectancies, and so, with fewer years in retirement, they would see a disproportionate reduction in their income. The effect might be particularly severe on those who have done manual work for long periods in heavy industries, in which there is a record of low life expectancy."

352. Responding to that report, our predecessor Committee commended the Government's decision, but added the caveat that "we consider it prudent to keep this particular issue and active ageing generally under review."[442]

353. We received evidence from a number of witnesses in favour of a rise in the State Pension Age, such as the CBI.[443] The Pensions Policy Institute commented that the original proposal to raise the State Pension Age to 68 to 2050 looked "modest."[444] The Actuarial Profession noted:[445]

    "A potential conclusion is that the Commission was less aggressive than it might have been in framing its proposals for SPA. For example, if it had instead targeted holding fixed the post-retirement life expectancy across the UK as a whole, it would have suggested SPAs of 70 for males and 69 for females by 2050".

Concerns about raising the State Pension Age


354. The TUC was opposed to any rise in the State Pension Age on the grounds that "differences in life expectancy mean that an across the board increase in the pension age would affect the poor the most."[446] This was echoed by some other unions who gave evidence to the Committee, for example the Royal College of Nursing,[447] the Public and Commercial Services Union[448] and the NASUWT.[449] Others opposed to the Pensions Commission proposal included the National Assembly of Women.[450]

355. The Independent Pensions Research Group Northern Pensions Resource Group commented that:[451]

    "The state pension is extremely important to the lower paid and women in particular whose labour market position is not strong. For those with assets and good private pensions, the state pension is almost irrelevant. Yet their labour market position is much stronger. Many older affluent professionals continue to work part time or as consultants trading on their knowledge and experience. It would be immoral to force the poorer sections of the population to wait longer for their state pension just to save some tax for the richer".

356. Age Concern argued that:[452]

    "steps to increase State Pension Age beyond 65 should not be taken unless: it is part of a clear package of improved state provision; health inequalities are reducing; the least well off are protected and there is a programme of action to facilitate later working".

357. The Equal Opportunities Commission and Help the Aged were more positive, although with some caveats. The EOC stated that it had:[453]

    "no objection to the principle of raising SPA which is a rational response to increasing longevity in women and men. However, any increases in SPA need to be linked to the life expectancy of the lowest socio-economic groups"

358. Help the Aged was generally supportive of the Pensions Commission approach, describing it as "credible" and "proportionate",[454] and asking for health inequalities to be dealt with in their own right by a "dynamic and vigorous campaign". However, it was critical in a supplementary memorandum about the "accelerated" line taken by the Government in the White Paper.[455]

359. The Government is clearly aware that raising the State Pension Age will have a greater impact on those from lower socio-economic groups, and stated in the White Paper that "analysis of disparities in life expectancy between different social classes and the relative effects on different social groups of increases to the State Pension Age"[456] could form part of the "regular reviews" described in the first section of this report.

360. When giving evidence to us the Secretary of State said "I know […] increasing the State Pension Age is a concern for many people, particularly members of this House who represent communities that do not have the same life expectancy as others. I do not think there is a magic wand, however, for this problem."[457]


361. Annex D of the White Paper sets out the extent and impact of demographic and societal change in detail, including tables showing how life expectancy has changed over time for all social classes. The DWP's memorandum to the inquiry set out the improvements that have already taken place across all social groups:[458]

    "Mortality rates between the ages of 60 and 69 for the generation born 1936-45 (current retirees) improved significantly from those experienced by the generation born 1896-1905. For Social Class I, mortality rates are down to just one-fifth of those faced by the turn-of-the-century generation; for Social Class V they are down to just two-fifths. During the period 1971-2001 men in Social Class I saw an improvement in life expectancy at 65 from 14.2 to 18.3 years, while those in Social Class V experienced an increase from 11.6 to 13.3 years".

362. However it was put to us that the differentials between groups were increasing. Richard Willets, Actuarial Profession, was clear on this point:[459]

    "The life expectancy of all socio-economic groups has improved quite substantially but it has improved, in relative terms, more for people in higher socio-economic class groups".
  • And he added later:[460]

    "If you consider life expectancy for people who have reached age 65, what is their further life expectancy, which is the most important measure in terms of pension provision, there still are very significant differences of at least five years between professionals and unskilled workers, and it is that gap that is widening at age 65".

363. Carol Jagger, Professor of Epidemiology at the University of Leicester, explained that these differentials also extended to 'Healthy Life Expectancy', a measure based on self-rated health. She told the Committee:[461]

    "There is certainly very good evidence that the differentials in healthy life expectancy are greater than the differentials in life expectancy for the different socio-economic groups. Whether that is changing over time we do not have good data to show that".

364. Richard Willets warned the Committee, however, that there were also very wide variations within socio-economic groups which would, for example, make deriving a measure based on individual class very difficult:[462]

    "I think also it is tempting to think of people in different classes being quite similar in terms of their life expectancy but even within the different social class streams there is a wide degree of heterogeneity, so for example if you took somebody in the professional classes who smoked and drank heavily and was overweight, they would probably have a shorter life expectancy than somebody in an unskilled occupation who did none of those things".

365. Kay Carberry, of the TUC, suggested that there should be a link between increasing the SPA and measures to make the labour market experience more conducive for older workers,[463] something we discuss in more detail in the next section of this report.

366. The Government has taken a bold step in proposing an increase in the SPA, given the lack of public consensus on this point. We conclude that the increase is justifiable. However, like many of those who gave evidence to the inquiry, we have concerns about the uncertainty of the projections on which execution of the policy is based, and we also fear that the policy will have a disproportionate effect on those in lower socio-economic groups, manual workers and those with health difficulties. We are also concerned at the potential lack of re-training packages and flexible job opportunities for those over 55.


367. The Secretary of State told us that:[464]

    "The Government has set out already some targets for tackling heath inequalities, which is the way that we have phrased it and the way that we would like to approach this problem, reducing variations in mortality between socio-economic groups, if there are already public service agreement targets to do that, and I think the Department of Health is making progress in that direction".

368. The Department of Health has a PSA target to "reduce health inequalities by 10% by 2010 as measured by infant mortality and life expectancy at birth." The PSA target is underpinned by two more detailed objectives:

  • Starting with children under one year, by 2010 to reduce by at least 10% the gap in mortality between routine and manual groups and the population as a whole; and
  • Starting with local authorities, by 2010 to reduce by at least 10% the gap between the fifth of areas with the lowest life expectancy at birth and the population as a whole.

369. The latest Department of Health Annual Report recorded a worrying lack of progress on the life expectancy target: "Data for 2002-2004 (three-year average) indicate that since the target baseline, the relative gap in life expectancy between England and the spearhead group has increased for both males and females, with a larger increase for females. For males, the relative gap increased by 1%, for females by 8%."[465]

370. The report added that there were "early signs of progress on some key disease areas and in some geographical areas" and also outlined priorities for future action:

  • "The targets included in the Department's PSA will strengthen the levers for progress, especially the new inequalities elements of the cancer and heart disease mortality targets"; and
  • "The Department's Health Inequalities Unit is currently working with PMDU and HMT on a review of the life expectancy element of the health inequalities PSA. This will include a detailed mapping of the delivery chain with the aim of improving our ability to achieve this element of the target. The review will result in a more defined and forward-looking delivery plan for health inequalities, and will influence our own review of the delivery of the infant mortality element of the target. A new Health Inequalities PSA Board is being established to drive delivery, using the review's recommendations as a platform for action."

371. The raising of the State Pension Age must be associated with a vigorous pursuit of the health inequalities PSA target. It must not be the case that by the time the State Pension Age rises, health inequalities have further increased. In our view, the achievement of the health inequalities PSA target needs to be a condition of a rise in the SPA, at least for those rises timetabled for the 2030s and 2040s.


372. The Pensions Commission acknowledged that a "one year increase in SPA has a bigger impact on people in the lower socio-economic groups than in the highest"[466] and considered in depth "whether any mechanisms [could] be created to mitigate the impact of a rising SPA on lower socio-economic groups."

373. One potential method which it identified "if there [was] no sign of the differences in life expectancy by socio-economic class reducing", was to keep "the earliest age of Guarantee Credit, at least initially, at 65 even as the SPA rises, and for thereafter keeping the earliest age of Guarantee Credit eligibility, say, two years below the SPA."[467]

374. This was originally a proposal from the Pensions Policy Institute.[468] Its memorandum stated that:

    "the PPI suggested keeping Guarantee Credit (GC) available a few years below State Pension Age. GC is available now at age 60, but the age of availability is expected to increase to 65 between 2010 and 2020 coincident with the increase in female State Pension Age."

375. Giving evidence to the Committee, Alison O'Connell (the PPI's Director) said that in her view this was the "most practical way of helping" those people in "lower socio-economic groups having lower life expectancy or worse health outcomes [who were not] able to work right up to the State Pension Age."[469]

376. The Pensions Commission acknowledged that the measure could reduce incentives to work but noted that that would only be for, say, two years and would only be applicable at fairly low levels of income.[470]

377. The White Paper noted the proposal but left a final decision for a later stage:[471]

    "We think this is an issue that must be considered nearer the relevant time in the light of the available evidence about inequalities in life expectancy and trends in working among older people."

378. Replying to a question about the position of those in lower socio-economic groups after his statement to the House, the Secretary of State said:[472]

    "We are aware of the issue to which my hon. Friend draws attention. The State Pension Age will reach 68 in 40 years' time and I am confident that his constituency and others will have a matching rise in longevity to meet that. The Turner commission suggested that we consider the issue of when Pension Credit becomes available, and the White Paper makes it clear that we are doing so, because that proposal might go some way towards addressing the concerns of my hon. Friend and others".

379. Keeping at 65 the age at which Guarantee Credit could be claimed could mitigate some of the impact of increasing the State Pension Age. However, we note the Pensions Commission's view that it could create disincentives to work. We agree with the Government that the decision on whether or not to increase the earliest age at which individuals can qualify for the Pension Credit in line with the State Pension Age should be made nearer the time when SPA may be raised, in light of evidence on both socio-economic differences in life expectancy and differences in labour market opportunities at older ages.


380. The evidence we received pointed clearly to the fact that predictions of life expectancy themselves come with a health warning. The DWP's memorandum referred to projections of future trends in life expectancy as being "notoriously difficult to make."[473]

381. Richard Willets of the Actuarial Profession told the Committee:[474]

    "One of the key learning points for the actuarial profession and for demographers and statisticians looking at trends over recent years is that life expectancy improvements are not certain; they are subject to a great deal of uncertainty […] I think the Pensions Commission report probably downplays a little bit of the uncertainty around the life expectancy of people retiring now at age 65. There is more uncertainty about their potential lifespan than is suggested in the report and going out to 2050 there are a huge number of factors […] that could influence life expectancy".

382. The National Heart Forum expressed concern that life expectancy could go down as well as up:[475]

    "We are witnessing an unprecedented change in the wellbeing and life chances of young people consequent upon systematic changes in lifestyle. These cannot have effects on mortality rates in the short term but are very likely to do so in the longer term, given what we already know about the epidemiology of many diseases . These changes are therefore not predictable from current trends in mortality and current health status of the workforce".

383. While, therefore, some witnesses such as PPI praised the decision to announce planned rises in the SPA up to 2044 because it gave people a decent notice period, others, such as Help the Aged, were critical.[476] The Pensions Commissioners stated that:[477]

    "The detailed implementation of this principle [that the SPA should rise over time to keep roughly stable the proportion of adult life spent receiving a state pension] should reflect future trends in life expectancy […] beyond the initial increase in SPA to 66 we believe that flexibility should be preserved to adjust the timing of subsequent increases in the light of latest life expectancy forecasts which may change over time."

384. We conclude that the uncertainty around future life expectancy is a powerful argument for the regularly commissioned reviews described in the first section of this report.

385. While some uncertainty around these figures is inevitable, the lack of clarity means that a clear case can be made for additional research. The National Heart Forum[478] made the case for "better understanding and better epidemiological modelling" to predict changes arising from new lifestyles. Professor Carol Jagger argued that there was a need for more research on differences in healthy life expectancy among different ethnic groups[479] and Richard Willets commented that there was a need for more "research into linking work on the aging process with projections of life expectancy and healthy life expectancy."[480] The Pensions Policy Institute told the Committee:[481]

    "A more detailed epidemiological model, working 'bottom up' from each cause of death would be required to increase our understanding of future likely trends. Further research on the 'bottom up' approach should be supported. Such a model would help to predict whether it is likely that future life expectancy improvements would be slower than those seen to date, or whether life expectancy would actually start to decline on average or for some groups (although a decline in life expectancy has hardly been seen in the developed world)."

386. The House of Lords Science and Technology Committee conducted a detailed and thorough inquiry on the Scientific Aspects of Ageing in 2005.[482] The Committee was highly critical of the lack of strategic co-ordination of ageing research, and made a number of specific recommendations to improve matters, following these up in a further report when it was unhappy with the Government's response.[483]

387. In a recent debate in the House of Lords on this follow-up report, the DWP Parliamentary Under-Secretary of State, Lord Hunt of King's Heath, made a number of commitments relating to future research into ageing. He told the House that:

  • The Government was "considering the role of an observatory on ageing to make best use of existing research and support the policy-making."
  • The Government would re-examine research council priorities in relation to budgets, expenditure and policy programmes in the spending review, and "use the Coordination of Research and Analysis Group and the longitudinal studies advisory group to improve research co-ordination and prevent duplication and overlap"
  • The Government intended to monitor closely the performance of the Funder's Forum for Research on Ageing and Older People [a body which was set up to extend the existing collaboration between the four research councils, six major charities and the Department of Health] and take action if it was "deemed not to be delivering".[484]

388. Specifically on the issue of life expectancy and healthy life expectancy he told the House that there was "no expert consensus about how the trend in healthy life expectancy will develop" and noted:

    "There is clearly a continuing debate about how best to measure health-life expectancy. There are two key measures; health-life expectancy and disability-free life expectancy, and I guess there are pros and cons of each approach. This is clearly quite complex territory. I accept that the challenge to the Government is to enable this to be pursued with care and speed. We will explore whether it is possible to develop harmonised measures of health-life expectancy with the World Health Organisation and other international organisations. We will also look to progress the committee's recommendation that ONS undertakes further work on the relative merits of different measures. We will continue to support research to understand trends and causes".

389. The White Paper referred to the evidence on healthy life expectancy as "incomplete".[485]

390. We ask the Government to set out the principal research programmes currently underway on ageing, life expectancy and healthy life expectancy, including work on differentials by social class and ethnic group, and their budgets for the next ten years. Improved co-ordination of research into ageing will also be vital to inform policy makers about future life expectancy and healthy life expectancy. We welcome the Government's commitments made recently in the House of Lords on these issues.


391. The Committee was warned that there could be unforeseen social consequences of the rise in State Pension Age on caring and voluntary work. The National Pensioners Convention noted:[486]

    "The unpaid caring and voluntary work undertaken by retired people that currently saves the Exchequer an estimated £24.2bn a year."

392. And they added:[487]

    "Raising the State Pension Age would also bear hardest on disadvantaged sections of the workforce and would reinforce the difficulties of women in their 60s with caring responsibilities for parents or grandchildren".

393. This was also a point made by Professor Carol Jagger:[488]

    "The fastest-growing section of the population is those aged 85 and over and the main carers of that section of the population are women. Given the mean age at first birth you are going to have women of 60 caring for their elderly parents (and it is potentially parents now as well). So if you are raising the pension age then those women are potentially still in work and doing a fairly major caring role too."


394. The Pensions Commission suggested that State Pension deferral could be beneficial to people on lower incomes who wanted to continue to work, by allowing them to draw part of their pension while deferring the rest. The Commission's Report stated that part of "ensuring good financial incentives for later retirement" could come from greater flexibility around the taking of the BSP and S2P and concluded:[489]

    "It is already possible to defer both the BSP and the S2P, receiving a higher pension at a later age or from April 2006 a tax free lump sum. But very few people know this, and at present the choice is inflexible: take the whole value of your BSP and S2P entitlement, or defer the whole pension.

    We recommend that there should be options to defer part of the pension while receiving part, and that a major publicity campaign should be launched to spread awareness of these options."

395. Responding to this point, the White Paper noted the additional flexibility for state pension and occupational pension deferral which had already been introduced:[490]

    "In April last year, more generous options for delaying taking the State Pension began, including for the first time the option of taking a lump sum. An individual who delays claiming their State Pension of £84.25 a week for two years could now get about £17.50 extra per week when they do claim, or they could receive a one-off taxable lump sum of around £9,300 plus their £84.25 a week pension. In April this year, we introduced changes to the rules of occupational pensions for those wishing to work more flexibly in the transition to retirement, so that (where schemes allow it) people can draw part of their pension while continuing to work for the same employer".

396. The DWP memorandum expanded on this explanation:[491]

    "People have always had the option of deferring claiming their State Pension at State Pension Age in return for a higher pension when they do claim. The 2004 Pensions Act provided for more attractive deferral options from April 2005. The rate of increment has risen to around 10.4% (from 7.5%) for every year a person defers. In addition, for the first time there is the option of a lump sum instead of a weekly increase where people defer claiming for 12 months or longer. The previous five-year limit on deferral has also been removed".

397. The White Paper concluded that the Government was "keen to see how the changes introduced last year to make State Pension deferral more generous will increase the numbers of people working and deferring, and will be undertaking research on this in due course." [492] It continued:

    "We will consider how State Pension deferral might in the future offer greater flexibility, both in terms of the amount drawn and deferred, and in terms of allowing people more flexibility to move in and out of work after State Pension Age. This second flexibility would mean offering people the chance to draw their pension when they need the income and defer it again when they can support themselves through work. However, this would increase complexity and will need careful consideration once research findings are available."

398. When asked about state pension deferral, Mervyn Kohler from Help the Aged told the Committee that "I think there is room for much more promotion than we have seen so far."[493] Research conducted by Norwich Union, and quoted in its memorandum, appeared to bear this out:

  • of respondents were unaware of the financial benefits to delay retirement available through the DWP State Pension deferral scheme; and
  • Once it was explained, 60% of people were influenced by the financial incentives on offer, and would choose to delay their retirement by a year if they were to receive the extra 10% per week throughout their retirement.

399. Citizens Advice expressed some concerns that this option would be "likely only to be attractive to people on middle incomes, who can afford to forego their state pension in anticipation that they will be able to continue to work for at least a further five years" and added "We might also suggest that any publicity for the state pension deferral come with a free crystal ball."[494]

400. The National Association of Pension Funds made a slightly different suggestion:[495]

    "As we argued in our response to the Commission's First Report, we believe that the current system for state pension deferral is the wrong way around. Behavioural economics suggests that, even if the sums of money involved were identical, people would be more likely to retire later if a bigger pension from a later age was the norm, with an option to take a smaller pension sooner."

401. We welcome the measures already taken by Government to provide more flexibility to people about the form in which they take their state pension. We also welcome the Government's decision to review the rules for state pension deferral with a view to, possibly, making the system more flexible. In our view this would be a sensible measure which would increase the options available to those nearing retirement. We recommend that the Government sets out its timetable for this review.

432   White Paper, para 3.34 Back

433   Pensions Commission, Second Report, November 2005, p 130 and p 240 Back

434   Q 358 Back

435   Q 358 Back

436   Q 207 Back

437   The Sun, May 26, 2006 Back

438   Evening Standard, May 25 2006 Back

439   Ev 365 Back

440   Ev 139, para 4.3 Back

441   Department for Work and Pensions, Simplicity, security and choice: Working and Saving for retirement, December 2002, Cm 5677, Chapter 6, para 49 Back

442   Work and Pensions Committee, Third Report of Session 2002-03, The Future of UK Pensions, HC 92, para 155 Back

443   Ev 356, paras 9-11 Back

444   Ev 391, para 11 Back

445   Ev 265 Back

446   Ev 200, para 1.42 Back

447   Ev 287, para 5 Back

448   Ev 331, para 27 Back

449   Ev 417, para 15 Back

450   Ev 288, para 5 Back

451   Ev 213 para 4.2 Back

452   Ev 317 para 2.22 Back

453   Ev 129, para 56 Back

454   Ev 166, para 6.1 Back

455   Ev 168 Back

456   White Paper, para 3.40 Back

457   Q 358 Back

458   The memorandum includes the caveat that Data on social class are derived from the ONS Longitudinal Study.Since data on life expectancy from this study are computed using the period approach, they might underestimate life expectancies as they ignore projected future improvements in mortality. The causes of the differences in life expectancy across social groups are complex and are linked to people's social, economic and demographic circumstances such as education, occupational health and safety, type of occupation, housing, regional differences, lifestyle choices, material deprivation, and access to health services. Ev 366, para 5 Back

459   Q 213 Back

460   Q 218 Back

461   Q 211 Back

462   Q 231 Back

463   Q 399 Back

464   Q 358 Back

465   Department of Health, Departmental Report 2006, May 2006, Cm 6814, p 17 Back

466   Pensions Commission, Second Report, November 2005, p 338 Back

467   Pensions Commission, Second Report, November 2005, p 340 Back

468   Ev 391, para 11 Back

469   Q 4 Back

470   Pensions Commission, Second Report, November 2005, p 340 Back

471   White Paper, para 3.42 Back

472   HC Deb, 25 May 2006, col 1666 Back

473   Ev 366, para 8 Back

474   Q 229 Back

475   Ev 253, para 4.1 Back

476   See para 358 Back

477   "The Pensions Commissioners welcome White Paper", Pensions Commission press release, 25 May 2006 Back

478   Ev 253, para 4.1 Back

479   Q 217 Back

480   Q 227 Back

481   Ev 391, para 12 Back

482   House of Lords Science and Technology Committee, First Report of Session 2005-06, Ageing: Scientific Aspects, HL (2005-06) 20, para 8.98 Back

483   House of Lords Science and Technology Committee, Sixth Report of Session 2005- 06, Ageing: Scientific Aspects, Follow up, HL (2005-06) 146 Back

484   HL Deb, 5 June 2006, col GC 322 Back

485   White Paper, para 3.41 Back

486   Ev 139, para 4.2 Back

487   Ev 139, para 4.3 Back

488   Q 233 Back

489   Pensions Commission, Second Report, November 2005, p 23 Back

490   White Paper, para 4.15 Back

491   Ev 367, para 13 Back

492   White Paper, para 4.32 Back

493   Q 127 Back

494   Ev 259, para 4.13 Back

495   Ev 305, para 66 Back

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