Dairy Farmers of Britain - Environment, Food and Rural Affairs Committee Contents


Memorandum submitted by Group from the DFB Members Council (DFoB 30)

SUBMISSION TO THE ENVIRONMENT, FOOD & RURAL AFFAIRS COMMITTEE

DAIRY FARMERS OF BRITAIN

  This report has been prepared on behalf of some members of the DFB Council (Separate list provided) without prejudice with the intention of giving information on some of the issues surrounding the DFB business. It is a mixture of fact and informed opinion and intended to give an insight into the business failure.

EXECUTIVE SUMMARY

  The business failed with debts estimated in excess of £100 million the larger part of this money is owed to the farmer members. The impact on individual DFB producers was proportionate to their size, and were as high as capital losses of £200,000 and bad debts of £100,000.

  As DFB was an important and integral part of the dairy supply chain its failure disrupted the market place and weakened prices for all producers and may also have indirectly encouraged more imports.

  DFB worked hard to establishing good governance. However the effectiveness of the different elements eg council, board and executive and their team work were questionable. The ultimate failure proved that the key ingredient of business acumen was missing.

  The prime cause was the price paid and the failure to assimilate ACC and generate sufficient cash surplus. This created an impossible burden of debt. In the period following acquisition the board strategy was based on further merger and consolidation and the board and executive did not grasp the management challenges which lead to economic failure.

  Government policy created the environment in which the co-op model was expected to work in a highly competitive market. The lesson to learn is that unless a co-op has a strong market position (As elsewhere in Europe) and has historic reserves of capital it can not compete effectively in the fierce UK market unless; it can move cautiously choosing market segments which do not bring it into direct competition with the plcs, European co-ops and the entrepreneur owned businesses.

1.  THE CAUSES AND LESSONS TO BE LEARNED FROM THE COLLAPSE OF DFB

Background

  1.1  With the government deregulation of the Milk Marketing Board (MMB) in 1994 the UK dairy industry entered a new era where the market controlled by the MMB's benign monopoly (from the farmers' view point) was replaced by a free market for milk.

  1.2  The process of deregulation initially saw the nationwide creation of Milk Marque a single dairy co-operative. However, due to concerns from the competitions authority over its dominant market position this evolved into three farmer-controlled regional dairy co-operatives, First Milk, Milk Link and Zenith.

  1.3  It is worth considering that co-operatives such as Fonterra in New Zealand and Arla in Denmark have over 95% of national milk supply and this strong market position is permitted. These businesses which have enjoyed strong market positions in their own country have developed to become international market players. (Including the UK market) They have had the benefit of substantial capital invested by several generations of farmers, possibly over 50-100 years of co-operative development.

  1.4  Strategically the decision to have three competing co-ops handed much of the power relationships in the supply chain to the retailers and as a consequence we have seen retail margins on dairy produce climb from around 6% to up to 50% during this period, largely to the detriment of farmers.

  1.5  The dismantling of the MMB saw the milk processing factory assets become part of Dairy Crest plc in which farmers became share holders. These processing assets which had been built during the period of MMB control had directly benefited farmers now they operated for the benefit of plc shareholders.

  1.6  This has had a huge impact on milk suppliers who indirectly paid for the investment in modernizing and developing the MMB's processing assets which were transferred to Dairy Crest. Much of the cost of reorganization and restructuring of the industry again is being indirectly paid for by farmers.

  1.7  There were no processing assets under farmer control through their newly formed co-operatives; they were simply milk brokers and administrators of the milk supply. As a consequence milk suppliers lost any effective means of returning financial benefit from further up the supply chain; they no longer enjoyed the financial benefit of processing. The DFB ambition was to achieve a significant position in the supply chain and thereby improve the market returns from farmers.

The Origin of DFB

  1.8  DFB came into existence from the merger of Zenith one of the three co-operative businesses set up following deregulation and another recently formed farmer controlled business called The Milk Group. It was set up with advice from Rabobank (A major European co-operative banker and adviser) and had many similarities with the New European co-operatives models. However in the UK it was obliged to operate within the restrictions of the UK Industrial & Provident Societies Act. (1965)

  1.9  Zenith operated as an effective milk broking business arranging and administering the collection and sale of member's milk to processors and customers across the region in which they operated. Their membership had evolved from the process of deregulation; some farmers made a positive decision to remain with Zenith their regional co-operative; others simply continued to supply by default ie the co-op continued to collect their milk.

  1.10  A significant number of co-op members were recruited during this period to become direct suppliers to plc processors and other private milk buyers. During this period direct milk buyers were able to return a better milk price than the co-operatives partly because the co-ops were carrying the cost of balancing the UK milk supply by jointly operating Westbury and providing a bottom to the market for surplus milk.

  1.11  The Milk Group came into being as a result of a number of larger producers being dissatisfied with their milk prices and coming together to form a new farmer controlled business. Their view was that their size and locations as producers would make them attractive to customers and allow them to develop a broking business capable of obtaining a better than average price from the market place.

  1.12  Milk Group enjoyed early success which saw them grow quickly to become a significant milk purchaser. They subsequently acquired two processing sites Nene Valley Foods at Peterborough a factory producing dairy ingredients and Lubborn in Somerset a specialist soft cheese producer. However, under performance of their two factories combined with an over supply of milk and an unanticipated down turn in the market saw them in some financial difficulties.

  1.13  The merger with the more financially secure Zenith in 2002 provided a solution for The Milk Group and theoretically created a stronger business. Potentially they could enjoy economies of scale and a critical mass for further acquisition and strategic consolidation of processing assets in the milk industry. Their aim was to improve their market position and deliver a better milk price to their milk supplying members.

  1.14  In the financial year ending 2005 the DFB business purchased in the region of 2 billion litres of milk from 3,200 member farms and was the third largest milk processor in the UK. Turnover at year end was £594 million with a group operating profit of £21.2 million after goodwill amortization of £2.5 million. It is significant that the majority of this profit £21.1 million was from the milk supply division.

  1.15  During the financial year ending 2005 the opportunity occurred to acquire the dairy processing business of the Co-operative Wholesale Society (CWS) This business the Associated Co-operative Creameries (ACC) was a predominantly liquid milk business of five processing sites at Blaydon in the north east, Whitby, Fole near Uttoxeter, Cardiff and Portsmouth. In addition there were two processing factories in Wales at Llangadog, a dairy product canning factory and Llandyrnog a cheddar cheese factory.

The Acquisition of ACC

  1.16  In September 2004 the acquisition by DFB of ACC was completed for circa £80 million with a budgeted profit potential at the time of £9 million pa. To finance the acquisition the members made substantial financial commitments and guarantees to the bank for total borrowings which would later exceed £100 million.

  1.17  The logic was that the acquisition of processing assets would give direct and immediate access to the significant market which ACC serviced. This market was approximately 1 billion litres p.a. With the significant indicated profit of £9 million at the time of purchase, it was recommended to farmers as an investment which would reward the member with better milk price returns and the potential for an investment income.

  1.18  Acquisition of the CWS asset gave access to what were perceived to be lucrative co-op retail liquid milk and cheese supply contracts, and the opportunity to build a long term relationship with a leading milk purchaser in the UK. In addition ACC had numerous milk supply contracts and relationships with other milk purchasers.

  1.19  In reality the purchase did not live up to expectations. The suggested ACC profit potential was never realized. Many of the purchased assets were in need of substantial investment and many of the management and working practices were outdated. In addition only two of the sites were purchased freehold; the other sites were on relatively short term leases. Their limited life made future rationalization of the business a future operational necessity.

  1.20  Furthermore the supply relationship with the co-operative group proved to be problematic particularly regarding pricing and direct to store distribution. The cost of delivery and service to their geographically fragmented store base was high.

  1.21  The ACC purchase in terms of scale was a massive acquisition by the newly formed DFB business which at the time only employed 180 people with little experience of operating a major processing business. The acquisition of a business with over 2,300 employees was a major undertaking. There was also a major culture gap between the management styles of the two businesses.

  1.22  Member council have expressed concern that the acquisition was over priced and that the due diligence process had not been sufficiently vigorous in several areas. These included a failure to appreciate the financial consequences of a long term milk supply agreement with Medina which had been agreed and signed immediately prior to the acquisition by the ACC business.

  1.23  The Llangadog canning factory in South Wales was closed almost immediately post purchase due to operational issues and financial losses; this undermined confidence in the acquisition. There were also environmental risks requiring significant capital investment following acquisition on several sites. Within three years of acquisition the loss making Whitby factory was also closed and should perhaps have been closed sooner to stem losses.

  1.24  The acquisition was costly and problematic in many areas. The executive failed to get prompt and effective control of the business and the financial requirements of the inefficient processing business created an economic burden on the business which impacted on milk price and undermined farmer confidence. The original purchase price did not leave the business with sufficient financial headroom to restructure and reorganize the loss making parts of the business.

  1.25  It proved difficult to get proper financial and operational control and understanding of the business. The ACC acquisition was poorly managed and failed to achieve the objectives.

The Acquisition of Lincoln Dairy

  1.26  The acquisition of Lincoln Dairy from the Lincoln Co-operative Society was made in addition to the ACC business in the financial year ending 2005. It was seen as an appropriate infill acquisition. Lincoln had a turnover of £23 million and an annualized volume of 50 million litres.

The Acquisition of Bridgend Dairy

  1.27  This acquisition in 2006 was made to allow the closure of the Cardiff dairy from the leased site to merge it with the newly acquired dairy business on the Bridgend site. This appeared to be good business; however the merger of the dairies was problematic in several areas. The effluent control on the new site required major investment and the merging of two employment cultures created management problems. The milk supply which was acquired with the new factory very quickly resigned to supply alternative milk buyers creating the need to import milk from further afield.

The Market

  1.28  DFB operated a defensive strategy on managing market fluctuations by having a broad base of products with short and long term contracts with a variety of customers in the liquid, cheese and commodity markets. This broad base of exposure meant risk was managed in a steadily moving market. However in a "spiking" market such as occurred in 2006-07 where commodities were rapidly increasing in value this strategy placed DFB at a disadvantage where more market adept competitors were able to pay significantly improved returns to milk suppliers.

The Customers

  1.29  Over the period of DFB's development a new team of managers and sales executives were recruited to join the business and manage customer's accounts. Through most of the period following the ACC acquisition customer relationships were good.

  1.30  In the key areas of product availability, quality and price DFB were consistently competitive and customers remained loyal. In particular the extensive depot and distribution system allowed the business to service key customers to a high standard.

  1.31  This ability to service customers did however come at a cost and although the commercial team achieved significant price increases and commercial successes; the high level of overheads in the business meant that although prices were market competitive the inefficient processing and distribution business was unable to deliver at a profit.

  1.32  Following the failure of the business to pay the dividends to members at the end of 2008 relationships deteriorated as customer confidence was damaged by further negative comments in the press and from industry commentators.

  1.33  In addition it has been suggested that the emphasis on building a relationship with Tesco for local choice milk diverted energy and resources away from relationships with core middle ground retail customers such as Spar and The Co-op and food service customers such as Brakes and Compass.

  1.34  At first sight the decision to pursue the local milk initiative with Tesco appeared to be an opportunity for DFB to play to strengths as a regional milk processor. The location of their medium sizes liquid dairies gave them the opportunity for regional milk which was attractive to retailers and consumers at a time when the market place appeared prepared to pay for the cost.

  1.35  However the demand placed upon the DFB business by Tesco to pursue an agenda for 18 local milks required dedicated local supply chains. The additional cost associated with this caused serious operational and processing problems. The costs incurred and the failure to achieve the volumes required ultimately contributed to the financial demise of the business.

  1.36  Tesco remained supportive to DFB throughout and remained a customer up to the time just prior to the receivers appointment. Perhaps if the initial ambitions of local choice had been more modest and the market had been allowed to grow gradually based in larger regions the impact on the processing business would have been more manageable and ultimately would have delivered a greater chance of success with less risk.

Government Policy

  1.37  The largest significant impact was the original deregulation which saw the creation of the co-ops and placed DFB head to head in a hugely competitive market place with well invested and highly capitalized public companies. With the heavy reliance on member debt and bank debt and little retained profit, the poor gearing and low capital base has meant that DFB struggled in what was effectively a Government imposed model where DFB was at a disadvantage and out competed and out-maneuvered by the plcs.

  1.38  The government has supported the creation of producer based co-operatives through several initiatives, however for a business operating on the size and scale of DFB these initiatives were of relatively little significance.

  1.39  This government deregulation and the subsequent evolution to three main co-ops and the movement of producers to direct supply relationships effectively handed the power in the supply chain to the major retailers to the detriment of the milk suppliers. DFB at the point of the ACC acquisition was the third largest UK processor but over the next four years was diminished as a market force.

  1.40  The way the co-ops were created and the evolution of their milk fields meant that the co-ops milk producers were smaller in size and dispersed geographically. This impacted on the economics of milk collection and distribution. This made them less competitive against the "cherry picked" milk fields of the plcs and other direct suppliers.

  1.41  The failure to review and update the Industrial and Provident Societies Act also impacted on the business.

Taxation

  1.41  Member capital invested in DFB was taxed and this had significant cash flow implications to farmer members. Take for example a member who invested £10,000 in DFB by capital retention deducted directly from his milk cheque; this money was lost in his cash flow but because it was counted as income was liable for income tax. In effect for every 10,000 invested the farmer could be liable for up to an additional 40% tax. On dairy farms operating on very low profit margins this had a substantial cash flow impact and was another significant reason for member resignations.

  1.42  If tax relief had been given to members' capital loans this would have assisted the development of the co-op particularly in the early years. The ambition of DFB to become a major milk processor using member loans as capital would have been assisted by tax relief or tax deferral as has occurred in other countries within the co-op sector.

2.  GOVERNANCE AND ACCOUNTABILITY STRUCTURES OF DFB

  2.1  At the formation of DFB advice was obtained from Rabobank a leading European co-operative banker and advisor. The business was intended to be modeled to replicate European Co-operatives. In reality it was a UK co-op regulated by the Industrial & Provident Societies Act. (1965)

The Members

  2.2  The elected member council was the ultimate governing body. It was encouraged to participate with regular meetings and a strong emphasis on training and development. In practice a lot of information was shared with council but there was on occasions a tension with the board over issues of commercial sensitivity. The council appointed the board who had delegated powers to appoint the executive and run the business.

  2.3  The member council voted in favour of the ACC purchase with a minimal amount of information provided to them on the day they were informed by the board of the intended acquisition. Concern was expressed by several council members that there was insufficient information or time to make an informed and rational decision on the acquisition. The council lacked experience or competence in this area.

  2.3  The problems following acquisition which undermined milk price also undermined member confidence and caused many members' resignations. At the end of the financial year in which Zenith and The Milk Group Merged (2004) the business handled almost 2 billion litres of milk from 3,200 farmers. At receivership five years later this was 1 billion litres and around 1,850 members. Of these remaining members almost half had resigned and were serving out their notice.

  2.4  The loss of membership and their capital contributions created further financial pressure. The capital base was weakened and the cash flow benefit of member retention was lost. Both factors were crucial in a highly geared margin managed business. In addition the capital structure of the co-op meant that the money already in the business as a member loan became a significant future cash liability.

  2.5  Despite these issues there remained a strong commitment by many members to make the co-operative work. Within the member council there were many who worked hard and diligently with little financial reward to improve communication and a more open and informed style of governance in the organisation. There was also a constant demand for the executive to provide more information on the business plan and to encourage a greater degree of transparency, understanding and accountability.

  2.6  There was a strong training culture and the member council fostered an environment for personal development and self improvement at council level. Many council members participated in training and worked to improve their knowledge and understanding of business issues and co-operative governance. Throughout the most difficult period immediately prior to the business failure the member council conducted themselves with considerable professionalism, integrity and dignity.

The Board

  2.7  The merger of Zenith and The Milk Group saw the creation of an interim board made up of farmer members of the two co-ops. The need for competent and experienced board directors and senior and executives was recognized and a recruitment and selection process commenced.

  2.8  Rob Knight was originally viewed as a potential CEO for which his previous experience was appropriate. His role as chairman of the Institute for Grocery Distribution was seen as a potential asset with the industry contacts it provided. He was subsequently appointed as board chair and he reorganized the board structure. The outcome was a board made up of a majority of relatively inexperienced farmer directors with non executive directors providing business experience.

  2.9  Following the acquisition of ACC the DFB board did not swiftly and decisively put in place a competent and effective executive to manage the enlarged operation. This probably undermined the future of the business.

  2.10  The over riding view of the board was that success would come from further industry consolidation through merger or acquisition. Considerable money was spent in consultancy and professional fees evaluating and trying to create the opportunity for a major strategic move to rationalize the industry. This strategic move was never achieved. The poor performance of the business also meant it was less attractive for merger.

  2.11  It has been suggested that the professional firms used for evaluating opportunities and advising DFB were insufficiently experienced in certain specialist area of business. This may have jeopardized opportunity for strategic development.

  2.12  There was also council concern that there was a board level conflict of interest. DFB board director Philip Moody was also a Director of Smith Williamson Corporate Finance who evaluated proposals and advised in these areas providing support to the chairman and board for considerable financial reward.

  2.13  The relationship between the board, executive and council appears to have been dysfunctional. With the benefit of hindsight it became clear that the under performance of the business was hidden from council behind issues of confidentiality. (A failing business has many secrets!)

  2.14  Despite this there were many efforts by council to achieve greater business transparency and accountability. For example a committee of the council submitted a paper to the board highlighting ways in which the capital structure could be improved. Following this submission a growing number of members of council felt the board and executive were out of touch with the genuine concerns of the membership.

  2.15  It has been also been suggested that the relationships in the board and the executive was not effective. There was council concern that directors at times operated more like executives. It is suggested that projects undertaken on cost reduction initiatives were not fully supported and implemented. Examples would be in the depot and distribution side of the business and HR plans to implement management key performance indicators and efficiency programmes on processing sites. It is not clear if this was due to lack of money to finance the initiatives or other reasons.

The Executive

  2.16  Following the ACC acquisition in August 2004 the CEO Malcolm Smith left the business in March 2005. This left a period of many months with this crucial position unfilled. During this period post acquisition the Board Chairman Rob Knight acted as executive-chair, but there appeared to be a failure to manage effective operational and financial control of the new business, The dual role was substantially financially rewarded with over £400,000 paid to the executive-chair in the financial year 2005-06

  2.17  This high financial reward combined with the subsequent poor financial performance of the business and its failure to pay a competitive milk price caused concern and resentment among members and was an important issue in further undermining their confidence.

  2.18  A new and relatively inexperienced CEO Andrew Cooksey was promoted from the internal role of Managing Director (previously Marketing Director). The chairman continued to receive significant financial reward while mentoring Andrew in the MD and CEO roles. The failure to get timely and effective operational and financial control of the ACC business during this period probably undermined many aspects of its future performance.

  2.19  It has also been suggested that there was too much emphasis on the DFB marketing strategy in the period following the appointment of the new CEO from a marketing background.

  2.20  There were not sufficient financial resources available to invest in major new product branding, development and marketing campaigns. However, there was still considerable promotional expenditure and recruitment activity which showed little or no return. This activity diverted executive time and energy away from the important area of effective factory level operational management in a processing business which was producing mainly generic dairy products.

The Employees

  2.21  In a failed business it is easy to assume that the employees underperformed or were ineffective in carrying out their duties. Within the organisational and management structure of DFB there were many people who in situations of considerable adversity carried out their duties in a thoroughly professional and business like manner. They operated effectively to face the business challenges and achieved notable success.

  2.22  In many other areas of the business such as in the restructuring and reorganization of cheese factories success was achieved. Aspects of the business management in areas such as risk management, auditing and health and safety management were ably managed and applied.

  2.23  However, there is no doubt that there remained in some parts of the business until the end a division between the old ACC business and DFB. A failure to address these different cultures and internal conflicts contributed to some extent to the businesses failing.

The Banks

  2.24  Relationships with the bankers throughout the early periods of DFB appear to have been good with the business working within the bank covenants and monetary constraints. The credit crunch and financial crisis of 2008 and 2009 had a significant impact on DFB.

  2.25  As a highly geared business experiencing cash flow issues they were vulnerable to a tightening of their credit facilities. This is particularly important where the business was heavily reliant on asset financed banking facilities.

  2.26  Where asset values are stable or growing asset financing is viable but as asset values deflate this financing method proved problematic. In the autumn of 2008 a change in bank personnel resulted in rigorous financial supervision. This coincided with a higher than budgeted level of cheese manufactured and held as stock at Llandyrnog.

  2.27  The demands on the cash flow necessitated the sale of cheese stocks into a falling market at a time when customers and intermediaries were also experiencing restrictions to their bank facilities. This forced sale of stock placed DFB at a serious disadvantage in the market and also fed rumour and speculation about the business which in turn impacted on customer, supplier and member confidence.

  2.28  This cash flow pressure meant it was not possible to pay members the interest payment on member capital accounts. This interest level was set high and proved to be a strategic mistake as non payment encouraged commentator's customers and members to further speculate on the position of the business. The lack of any kind of financial buffer to weather these short term cash flow problems made the business vulnerable. The delayed payment of creditors during this period made the situation worse.

The Business Advisers

  2.29  It proved very disappointing that despite the board investing millions of pounds in professional services and advice from individuals and business advisors over several years that the business failed to achieve the creative strategic solutions required. These advisors were unable to provide a managed solution to the problem for the business which avoided it being placed into administration.

  2.30  There has also been concern expressed that the money invested in an effort to find a creative solution was in later days used to prepare the business for receivership. Perhaps the broader question should be asked is it appropriate or could it be considered a conflict of interest for a business to be offering business advice to be then appointed receiver and manager. This is not a point exclusive to the DFB situation.

  2.31  In the last few months that the business continued to operate PWC were tasked with selling factories particularly those in the liquid business. The failure to bring these intended sales to completion ultimately sealed the fate of the business because the continued cash loss of supporting these loss making factories was unsustainable. This was particularly important as the customer base disappeared as confidence fell. The business was forced to sell more milk into spot liquid and commodity markets at poor prices.

  2.32  In addition to the companies tasked with advising the DFB board a number of individuals with specialist skills were given board positions or employed as advisors to the board.

3.  THE IMPACT OF THE COLLAPSE OF DFB ON DAIRY FARMERS AND THE INDUSTRY

  3.1  The loss of confidence has impacted on farmers and the broader industry. As a direct consequence of the business failure, around 50 members ceased milk production almost immediately and in the region of another 150 are currently managing their exit from the industry. There has also been an impact on the confidence of other co-op members who have concern for the future of their businesses which also carry significant debt burdens.

  3.2  The amount of total capital retained from members was £65 million a contribution of up to 4ppl for each member. For an average producer with an annual production of 700,000 litres milk this represented £25,000 to £30,000 however individual members production levels ranged from 200,000 litres pa up to 5,000,000 litres and therefore capital losses for some members will be up to £200,000 of capital contributions.

  3.3  In addition to this the members were paid a milk price below the market average. Over a four to five year period this represented revenue lost to their businesses and was effectively a further subsidy to the business equivalent to another £60 million.

  3.4  The loss of cash flow from the failure to pay the June milk cheque and the low milk price paid during receivership is a serious bad debt which will range in quantum from a few thousand pounds to in excess of £100,000 for larger producers and has had a serious impact.

  3.5  All former DFB producers have entered into new milk supply contracts and whilst some are satisfactory a substantial number of farmers are being paid on market spot prices, this is having a continuing depressing impact on their incomes.

  3.6  The market place was impacted by the failure of DFB because it caused dislocation of the arrangements for milk supply. This created surplus milk which in turn weakened the market for all suppliers. DFB was a major player in milk industry logistics and within the complex structure of UK milk supply the loss of the business has had a negative impact on the cost efficiency and organisation of dairy industry milk collections.

  3.7  This market dislocation also created the environment where major customers are encouraged to turn to imports on a larger scale.

  3.8  Including job losses in the past 12 months there have been a total of around 2000 jobs lost at DFB. There have also been consequential job losses in suppliers directly to the DFB business and also to the businesses supplying the farmer members.

  3.9  Farmers who have lost capital and revenue have been compromised in their ability to reinvest in their own farming infrastructure which will have implication for the longer term sustainability and competitiveness of their businesses.

  3.10  The bad debt of four weeks lost milk revenue and consequential losses to DFB members is equivalent to around £20 million. This has had an impact on farmers suppliers who are owed money by DFB members and is revenue lost throughout the rural economy.

4.  DEFRA'S RESPONSE TO THE COLLAPSE OF DFB

  4.1  There was little public evidence of DEFRA intervening although we believe that they were fully briefed. However, future consideration should be given to the impact this failure has had on milk supply and the loss in ability of UK agriculture.

  4.2  The Welsh Assembly Government has agreed to pay single farm payment to DFB members in October which will aid their cash flow. To date no similar commitment has been made for English Farmers.

Note:

  A number of questions were separately submitted to PWC by DFB council members and it is suggested that a request is made to PWC for a list of these questions and their response.

  End:

  This report was compiled on behalf of the members of DFB Council listed separately.

Group from the DFB Members Council

August 2009



 
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