Alcohol - Health Committee Contents


Further memorandum by ASDA (AL 22A)

  Ahead of our opportunity to submit oral evidence to the committee, we respectfully ask you to consider the following written evidence from ASDA which explains our position on the main aspects of the Committee's terms of reference and some of our wider views on the retailing of alcohol. We have also included as an Annex to this evidence our views on the Government's proposed mandatory code.

We understand the terms of reference for these hearings are to be focused on:

    — The scale of ill-health related to alcohol misuse.

    — The consequences for the NHS.

    — Central government policy.

    — The role of the NHS and other bodies including local government, the voluntary sector, police, the alcohol industry, and those responsible for the advertising and promotion of alcohol.

    — Solutions, including whether the drinking culture in England should change, and if so, how.

  ASDA is the UK's second largest supermarket operating close to 370 stores (some of which are non food), employing 170,000 colleagues, and serving over 17 M customers every week.

  We have always been willing to work with Government to tackle alcohol misuse. We are ready to create a new way of selling alcohol, but this new way must not disadvantage the majority of drinkers who consume responsibly and do not cause public disorder.

1.   ALCOHOL CONSUMPTION AND HEALTH

  The debate has traditionally focussed on the link between excessive alcohol consumption and crime and anti social behaviour. The practice of binge drinking has clear health impacts for the individuals concerned, for the health service and for wider society through antisocial behaviour and the resulting strain on public services.

  There has, however, been an increasing interest in the long term health implications of regular over consumption above recommended daily and weekly guideline amounts. This concern applies not only to younger age groups traditionally associated with binge drinking but also to middle aged and retired groups who are not generally associated with crime and antisocial behaviour.

  To date the approach of Government has been to target policies at reducing the health and social consequences of binge drinking. Recent interventions by the Chief Medical Officer in support of minimum pricing has concentrated more on the need for an across the board reduction in alcohol consumption, which it is argued is best achieved through pricing mechanisms.

  While we understand the concerns of health practitioners and policy makers about the impact of excessive alcohol consumption in the UK, we do not believe that the answer lies in pricing mechanisms. In fact, we believe that there is a real danger that an overly simplistic concentration on price as the key driving factor of consumption risks missing some of the social and cultural factors which have a much greater impact on patterns of alcohol consumption in the UK.

Consumption is declining

  Alcohol consumption in the UK is decreasing. Recent statistics from HMRC show that there has been a significant decline in per capita consumption from a high point in 2004 to 2008. In fact overall consumption reduced by 5.1%.[20] This decline in consumption has been seen in all alcohol categories with the exception of cider. Beer is down 8%, wine down 3.6%, spirits down 3% and Flavoured Alcoholic Beverages (FABs) down by an even greater 22.4%. This decline has not received the attention it deserves.

  There appears to be a paradox whereby declining alcohol consumption is not mirrored in improving alcohol related health statistics. Neither has there been any concerted effort to map reductions in consumption with increasing duty on alcohol over the same period. These are issues which we believe require further investigation if there is to be a rational debate on the link between alcohol consumption and the health of the wider population.

Patterns of consumption have changed

  To understand changing patterns of alcohol consumption in the UK it is first important to understand the wider social and cultural changes seen in the past decade. There has been a significant shift away from on trade to off trade sales of alcohol. Since 2001 household consumption figures show that alcohol consumption in the home has risen from 735ml per person per week to 772ml in 2007. Over the same period, consumption outside the home has reduced from 733ml to 503ml While this is a significant shift, it is our belief that there is a common misconception that this has been driven purely by price competition between supermarkets and pubs.

  Evidence would suggest that the traditional pub business model has faltered as it has proven inflexible in meeting growing costs in its supply chain and operating model. As a consequence price increases for customers have resulted as pubs are forced to make up lost margins through higher prices for customers. Supermarkets have taken much of the blame for the failure of the traditional pub model to compete. We do not believe that this blame is accurate. As the evidence suggests it is simply a matter of increasing charges for customers by the on-trade sector and changing customer preferences.

Social and cultural change behind changes in consumption

  The decline of on trade business is not the fault of supermarkets. It is plain to see that there has been a wider cultural shift away from the pub as the hub of the community. This has been exacerbated by some external factors including the ban on smoking in public places. Increasingly we hear from our customers of their desire to socialise with friends and family in what they see as a safer, more controlled home environment. Fear of antisocial behaviour, greater awareness and enforcement of drink driving laws, the growth of dinner party culture and an explosion in digital broadcasting and compelling TV scheduling are just some of the factors driving the growth in consumption of alcohol in the home.

  The family home or garden is increasingly seen by our customers as their preferred "destination" for socialising in groups which can include wider family and friends as well as children—often not properly accommodated in pub settings. It has been suggested by some that pubs are a safe, well regulated drinking environment and that shifts to home drinking are therefore negative because the home setting is unregulated. That is not the view of many of our customers who believe the opposite to be the case. They view drinking with family and friends in the home as an inherently safer choice than drinking in town and city centres which they see as a riskier option, bringing them face to face with antisocial behaviour and crime.

  Drinking in the home is now an established social norm. The Joseph Rowntree Foundation report A minimum income standard for Britain[21] sought to establish what the public considered was necessary to achieve an acceptable standard of living.

  The report considers four different household types: single working age, pensioner couple, couple with two children and lone parent with one child. Focus groups decided that for each household type some level of spending on alcohol was necessary to achieve an acceptable standard of living (p.18). In the case of a couple with two children, it was decided that only alcohol for consumption in the home was a necessity (p.33).

  Their findings remain true in this year's report[22] and additionally the report notes that focus groups suggested there is now a lower expectation about how often working age people go out for entertainment.[23]

  We believe that these wider social and cultural changes better explain the shift away from pubs to home drinking than a simplistic argument on price competition.

The importance of value—not penalising the responsible majority

  We believe that the majority of our customers purchase and consume alcohol responsibly. An irresponsible minority are responsible for the vast majority of alcohol related costs to society. In the UK 7% of the population drink 33% of the alcohol. We believe that this requires a targeted approach which identifies those who have a disproportionate impact on society and attempts to address their behaviour based on a proper understanding of the social and cultural factors which influence that behaviour.

  We believe that policy makers should be careful not to adopt blanket policies which punish the majority for the behaviour of a minority.

  We are concerned that the most responsible, law-abiding consumers are the ones who will lose out, and that individuals who create public order disturbances will continue to do so. In particular, it would be a severe unintended consequence for low income shoppers already hit by rising utility costs, rising fuel and food prices if new regulations were to hit responsible drinkers in lower income groups.

  Indeed there is evidence that lower income groups are not responsible for the bulk of alcohol consumption, but are least able to afford alcohol. Therefore, low income households are disproportionately affected by rising prices and tax increases. The General Household Survey 2007 reported the percentage of adults who drank more than eight (men) six (women) units on at least one day in the last week by household income bands. The average for all income groups was 20%. However, for households with less than £200 per week income the percentage was 11%. This figure rose steadily by income bracket to 28% for households with a weekly income above £1,000.[24] Raising the price of alcohol will have a disproportionate effect on low income households. In a time of recession, the concept of affordability is not as relevant to those on low incomes for whom very few luxury goods are truly "affordable".

  The introduction of new price controls such as a ban on promotions or minimum pricing would further reduce the disposable income of low income groups but, unlike with duty, would not deliver a single additional penny of revenue to the state.

  We would urge the Committee to recognise the benefits of competition to a whole swathe of customers from low income backgrounds who purchase and consume alcohol in a responsible manner.

2.   PRICING AND CONSUMPTION

  There are many myths in the debate around supermarkets and alcohol pricing. Some commentators have said that our lager is cheaper than our water. This is not the case. Our Smart Price lager is priced at 91p for four 440 ml cans—52p per litre (and we have reduced the strength of this lager to 2% ABV). A 2-litre bottle of Evian water is 78p—39p per litre. So, even our cheapest lager is more expensive than Evian. And it is even more expensive than our Smart Price water, which is priced at 13p per 2-litre bottle—6.5p per litre.

  Others make the claim that supermarkets are promoting alcohol at pocket money prices. Yet supermarkets have led the charge on underage sales through the establishment of Challenge 25 to reduce the availability of alcohol to those under 18. It is unfortunate that some commentators have sought to muddy the waters on price and availability to under 18s. A worrying number of under 18s consume alcohol sourced for free from parents or friends and therefore the issue of price does not seem to be a key factor on whether under 18s wish to and succeed in consuming alcohol.

Promotional activity

  On 1 September 2009 the Licensing (Scotland) Act came into force and introduced a ban on all happy hours and promotions in the on trade in recognition of the fact that certain promotions in the on trade were "irresponsible" because they encouraged people to consume more alcohol in a shorter space of time.

  There is a significant difference between promotional activity in pubs and clubs and that in shops. Promotions in the on trade are de facto about immediate consumption—an additional bottle of beer, free pint or glass of wine, or double for the price of a single shot cannot be taken off the premises. It can only be consumed there and then by the person or persons receiving the deal.

  Promotions in the off trade on the other hand are often used by customers who are seeking good value but who purchase the alcohol with a view to consuming it over a longer period of time or with a wider group of family and friends. When a customer takes advantage of a quantity discount, it does not mean that they will consume that alcohol immediately. Indeed many customers stock up and consume alcohol over weeks or months. That is a fundamental difference between promotional activity in the on and off trade. Contrary to some media reports, ASDA does not run Buy One Get One Free offers on alcohol. We do offer value to customers on individual lines and through some quantity discounts such as three bottles of wine for £10. We do not believe this is an irresponsible promotion. Indeed the promotion allows customers to benefit from higher quality wines for a lower cost.

  As stated in our evidence on the mandatory code, we are concerned at proposals for local discretion on promotion bans in the off trade which we believe would distort competition, inconvenience and confuse customers, raise costs to business and lead to an unfair postcode lottery.

Minimum pricing

  It is worth reiterating that the notion alcohol has become cheaper is actually caused by an increase in affordability—it is not that alcohol in itself has got cheaper. Government published data shows alcohol has actually increased in price. Since 1987 alcohol price inflation has exceeded RPI and has risen substantially more than food inflation. The difficulty is that average earnings have gone up faster than RPI making alcohol more affordable.

  The Committee has already heard evidence in favour of the introduction of minimum pricing of alcohol and restrictions on promotional activity.

  We believe that there is a real danger that minimum pricing is seen as the "silver bullet" and that an over concentration on price mechanisms neglects some of the much wider social and cultural factors behind alcohol consumption. It is self evident that there is some link between price and consumption, however we believe that this case has been significantly overstated. Ultimately the extent to which minimum pricing (if it were to be introduced) would drive changes in consumption would depend on the level at which it is set. We are sceptical that at levels of 40p or 50p per unit significant behavioural changes would follow. All that such a price would do is penalise hard working families on low incomes.

  Minimum pricing is a system which exists in no comparable country on a nationwide basis. It is based on theoretical modelling which does little to take into account the prevailing cultural and social norms in the UK. Price elasticities are affected by many factors and, we would argue, apply in differing degrees to different groups in society. We believe that there are many unintended consequences of minimum pricing which make a seemingly simple concept a much less effective policy solution than theoretical modelling results might suggest.

  As previously stated, alcohol consumption is declining in the UK even at a time when competition and good value deals are seen across the off trade sector. Arguments for minimum pricing essentially follow the logic that price drives consumption and consumption leads to health problems across the population. Yet it is not a straightforward relationship. Statistics on alcohol related mortality in different parts of the UK clearly show a much higher rate in Scotland than the rest of the UK with a significantly higher rate of increase in recent years at a time when trends have levelled off in England. This is puzzling as average incomes in Scotland remain significantly below the UK average, yet alcohol prices in Scotland are in line with those across the UK. ASDA sells products at a single price no matter where our stores are located. Therefore alcohol is a proportionately more expensive commodity to people in Scotland than England, yet alcohol related morbidity rates are higher. There are clearly other social and cultural factors at play.

  Proponents of minimum pricing have used competing arguments to supports its introduction. On the one hand it has been described as merely raising the price of the cheapest alcohol. On the other it has been described as a solution to the problem of over consumption among the entire population including middle aged and older drinkers who are not generally associated with the purchase of the cheapest alcohol or with antisocial behaviour. Indeed the subject of rising consumption in the over 45s age group raises an interesting question about the link between price and consumption. This group generally has higher levels of disposable income than younger age groups and therefore there is a real question as to what extent their consumption is driven by price. Would a 20 pence increase in a bottle of wine really reduce consumption in this target group? Are there other factors involved in rising consumption among this group?

  We recognise the concern among policy makers about sales of the cheapest alcoholic products. In an active and competitive market place, it is difficult for any one retailer to unilaterally address pricing without putting itself in a position of competitive disadvantage. At the same time, it would be illegal for supermarkets to get together and discuss multilateral increases in price. If the Government wants a system whereby it is illegal to sell below the level of alcohol duty plus VAT then this would have to be mandated.

  This is entirely a matter for government to consider. However, we would argue that while a system of minimum pricing has the disadvantage of returning no additional revenues to the state—effectively privatising the profit and socialising the loss—a system of duty plus VAT allows for revenues to be returned to the state and invested in alcohol education, awareness, diversion and treatment programmes.

Personal Responsibility

  Promotions and pricing are not in themselves irresponsible, it is how individuals consume the alcohol that they purchase which is important. Many of our customers take advantage of offers and consume the alcohol responsibly. We accept that there are instances where some abuse alcohol purchased from the off trade. However, does that mean that nobody should be able to take advantage of good deals? Many of our customers have told us they believe that pricing mechanisms that increase prices for customers smack of a "nanny state" approach and they are sceptical that these measures will tackle the real problem drinkers (see Appendix One). To truly change the culture of drinking, customers need to believe that changes will be effective and are being done for the right reasons. There is a danger that too much of a reliance on price misses the point about personal responsibility. Whether a can of lager costs 50p or £3 is no excuse for somebody to drink to excess, or engage in anti social behaviour.

3.   INFORMATION, EDUCATION AND RESPONSIBLE RETAILING

  At Asda we recognise that we have a duty to be a responsible retailer of alcohol and to work with Government to ensure that our customers are able to make informed choices when they shop with us. We believe that changes to the drinking culture in the UK must be driven by improved education, increased awareness, diversionary activities, and quick and effective treatment for those who have alcohol problems.

  We would like to reiterate some of the actions we have taken which demonstrate that we understand our responsibilities as retailers of alcohol. ASDA has already delivered eight key voluntary measures to ensure that we live up to these responsibilities. These include measures which are designed to reduce underage sales, reduce crime and antisocial behaviour, and educate our customers about responsible drinking and health. They include:

    1. the first national roll-out of Challenge 25;

    2. stopping selling alcohol at 100 of our town centre stores between midnight and 6am (as highlighted in Policing in the 21st Century);[25]

    3. a fund to help educate young people on alcohol misuse;

    4. a doubling to 4,000 independent test purchases of our own people per year;

    5. the delisting of some products and reduction in alcohol content of others;

    6. introduction of the new UK Department of Health (DH) recommended wine label on our own brand wines—the first retailer to do this, and well ahead of the main brands of winemakers;

    7. regularly providing information on responsible drinking through the ASDA Magazine, which has a readership of 5 million throughout the UK; and

    8. The banning of "% extra free" alcohol packs.

Increased display of health messages

  Asda has pioneered the use of labels on our own brand wines to communicate the number of units in a small glass, a large glass, and a bottle of our own brand wine. In addition, we have already incorporated the DH pregnancy message on many of our labels.

  We have a strong record of providing health information to customers on a range of issues such as alcohol and nutrition. We give information to customers through point of sale material and articles in our monthly "ASDA Magazine " read by approximately five M people. It has the highest circulation of any women's monthly title in the UK and was read by almost a quarter of UK households in 2008. In addition, we update our website with sensible drinking messages, especially around Christmas and New Year when consumption is traditionally higher.

  We happily support any attempt to give customers more information on sensible drinking as we believe that education for customers is key to tackling this cultural problem. Our concern is that a prescriptive approach may spoil the good work that is already underway through initiatives such as Drinkaware and the Campaign for Smarter Drinking, where we are already linking sensible consumption levels to the DH labels on products.

  We are financial supporters of the "Campaign for Smarter Drinking" and have already committed to placing point of sale in the alcohol aisles with responsible drinking messages included. We offer our support to any educational aims in Government policy, but we would urge the Government to accept this Campaign for Smarter Drinking point of sale material as suitable in meeting these aims.

  We believe that there is an opportunity to do more to educate customers about the health implications of alcohol consumption through product labelling. Traffic light labelling on food products has improved our customers' understanding of the food that they eat and the need for a balanced diet. We believe that there is scope to extend a similar system to alcohol products in order to improve awareness and point customers towards lower alcohol products. There is also an opportunity to choice edit before the point of retail by looking again at the potential scope to reduce the alcoholic content of a range of products. For example Asda has already reduced the alcohol content of our smart price beer.

ASDA's Social Hurdle

  We support the idea of a "social hurdle" approach requiring retailers to have a proactive approach to the tackling of alcohol misuse through a series of individual initiatives. There is no reason why such an approach could not include a strong health element.

  In summary we propose that instead of imposing any kind of financial levy on retailers, or price interventions which raise the cost of alcohol for customers, policy makers should instead consider a social responsibility hurdle that:

    (i) must apply to all licensed premises;

    (ii) must allow for additional expenditure by retailers on managing alcohol sales to be offset. Otherwise, we will see a race to the bottom in terms of important and creative voluntary measures by business;

    (iii) must be mindful of extra cost burdens on our customers; and

    (iv) must apply to the producers and distributors of alcohol products elsewhere in the profit chain.

  The potential benefit of the social hurdle approach is that it creates real incentives for those involved in the sale of alcohol to come up with creative and added value measures to tackle the misuse and abuse of alcohol. It avoids the introduction of new taxes which would lead to higher prices for consumers.

  As an example of the type of social responsibility work that we have funded, we recently gave £20,000 to the new community disorder bus in Toryglen in Glasgow and hosted a major community event for its launch. We have also made a financial commitment to a bus in Burnley in east Lancashire. These projects are aimed at diverting young people away from alcohol by giving them alternative alcohol free activities in their own communities. They could also have a role in educating young people about the health implications of over consumption.

  We would suggest that the recent experience on carrier bags offers an insight into the willingness of business to work hard to meet voluntary targets. Government and industry set a 50% reduction target in bag use in our stores. The industry as a whole only just failed to meet what was a challenging and difficult target which required significant effort, financial investment and engagement with customers. Different retailers were able to employ different measures which fitted with their business models in order to meet the same goal of reducing bag use. There are good lessons to be learned from this approach and in principle there are few reasons why a similar approach could not be applied to social responsibility and alcohol.

Reducing availability for under 18s

  It is clear that early exposure to alcohol can have a disproportionate effect on health as children's bodies are unable to cope with alcohol in the same way as adults. Children who start consuming alcohol at an early age can face significant health challenges in later life and there is growing evidence of much earlier incidences of liver disease.

  That is why it is so important to reduce the availability of alcohol to under 18s. Asda was the first national retailer to introduce a Challenge 25 scheme where proof of age is required by any customer who looks under the age of 25. This has now been adopted across the industry.

  It has been suggested in the mandatory code that Challenge 21 should become mandatory for all retailers. We do not support moves which would move back from the current Challenge 25 position which we believe is far more robust and easy to administer by store colleagues. We would therefore suggest that if such a scheme were to become mandatory it should follow the existing Challenge 25 system established by retailers through the Retail of Alcohol Standards Group (RASG) on a voluntary basis to tackle under age sales. Many retailers are now moving to challenge 25 to reduce age recognition problems further—following the lead established by Asda. We wholly support this move to Challenge 25, and we believe that all retailers of alcohol (whether on or off trade should adopt this scheme).

Paul Kelly

External Affairs and Corporate Responsibility Director

September 2009

Annex 1

VIEWS ON THE GOVERNMENT'S MANDATORY CODE

SUMMARY OF ASDA'S POSITION ON THE ALCOHOL MANDATORY CODE

  On the whole we believe it contains a sensible set of measures designed to help tackle the problems caused by the misuse of alcohol by the minority. We do however have serious concerns about some aspects of the code.

    — We are against a ban on promotions for alcohol which is locally set. A locally controlled minimum price is dysfunctional on competition grounds. Two stores—most likely within a ten minute drive time of each other—would not be able to effectively compete if one has a local ban on promotions which does not affect the other. (Ten minutes drive-time is the Competition Commission definition of a relevant competition market in grocery).

    — A locally sanctioned promotions ban would not be proportionate in the amount of burden placed on business. A multiple retailer operating a single price point across the UK will find this logistically exceptionally burdensome to implement.

    — A ban on promotions disproportionately affects those on low incomes and is unfair. A severe economic recession combined with price controls has real unintended consequences for customers.

    — Those affluent customers with access to the internet will be able to escape these promotional bans (as they will not have to visit a retail premises) and that cannot be fair to the consumer or to non-internet retailers.

    — Actions such as those envisaged in the code could seriously distort the local grocery market. The code also makes no mention of the rewards given through loyalty cards and money off vouchers. These factors must be considered if there is any possibility of a level playing field between retailers. A local promotions ban that discriminates between legitimate business models no longer has alcohol abuse control at its heart, but becomes a dysfunctional disruption of the market. We are very concerned that local authorities will be tempted to avoid action against retailers operating loyalty cards because intervention would be too complicated. Councils will focus efforts on "easy targets" ie those retailers with straightforward promotions.

    — We believe that if the Government wants a floor level of duty plus VAT, then this would have to be mandated. We know that this could never be achieved through a voluntary agreement.

    — We believe that local licensing conditions should be formed out of a discussion between local licensing officials and individual retailers about the most sensible conditions for that area, and not based on blunt economic tools like a promotions ban. For example, consider our "Eastlands model". We have a store in Manchester—next to the City of Manchester football stadium. This store will have particular local needs which can't be dealt with through a national scheme of promotional controls—even though these may be locally administered. The proposed local conditions are too blunt a tool and create competition issues which are not adequately dealt with.

    — It is essential that in the event promotions were to be banned that guidance notes be issued to licensing authorities making it clear how the ban should be implemented to avoid a market distortion. (The planning regime offers a potential model in PPS6, advice that must be followed by councils in order to deliver the objectives of the national policy). We set out conditions that local authorities should follow if they choose to ban promotions later in our response.

    — We believe that a refusals register would be unworkable, too prescriptive, and against the principles of better regulation. Specifically, it is not appropriate to the risk posed and is excessively burdensome.

    — ASDA has represented value for over 40 years and is sincerely opposed to lower income consumers bearing the brunt of these proposed changes. In this time of recession, we do not think that hard-pressed, law-abiding customers should be asked to pay more for alcohol as a result of a promotional ban. We strongly believe that competition on price and on promotions is positive for consumers. They have clearly told us that they would be concerned if Government initiatives were to put this at risk—please see appendix one to see our survey of 10,500 customers.

APPENDIX ONE

  ASDA customer survey. We commissioned an independent market research organisation to ask 10,000 of our customers their views on the key proposals put forward by the Scottish Government. The results of that survey are shown below:

RESULTS OF ASDA CUSTOMER SURVEY

  This survey consisted of 10,109 face-to-face interviews conducted with ASDA shoppers in 30 stores throughout Scotland. All interviews were conducted between 15 and 29 August 2008. The research was conducted by Market Research Society-trained interviewers from the Ace Fieldwork market research agency.

1.   The Scottish Government is concerned that alcohol is currently too cheap. The Government wants to set a fixed minimum price for alcohol to reduce the amount people drink. What do you think of this proposal, do you agree or disagree with it?
1.  Agree3,385 33.5%
2.  Disagree6,170 61%
3.  Don't Know549 5.4%
4.  No answer50.0%


2.   The Government is also proposing to ban multi-product promotions (eg "3 for 2" and "Buy one Get one Free") to reduce the amount people drink. What do you think of this proposal, do you agree or disagree with it?
1.  Agree2,97829.5%
2.  Disagree6,818 67.4%
3.  Don't Know309 3.1%
4.  No answer40.0%


3.   Of the two proposals outlined above (minimum pricing, and the banning of promotions), which do you think would be the most effective in reducing alcohol consumption?
1.  Minimum Pricing1,772 17.5%
2.  Banning Promotions1,997 19.8%
3.  Neither6,017 59.5%
4.  Other2842.8%
5.  Both270.3%
6.  No answer120.1%


4.   The Scottish Government is considering that from September 2009, supermarkets would not be able to sell alcohol together with other items. This would mean customers would buy alcohol at a separate checkout and make two separate transactions. Do you agree with this proposal?
1.  Agree2,19021.7%
2.  Disagree7,405 73.3%
3.  Don't Know507 5.0%
4.  No answer70.1%











20   HMRC/BBPA, Alcohol consumption, 1990-2008, litres per head of 100% alcohol Back

21   Joseph Rowntree Foundation-A minimum income standard for Britain, July 2008. p18 Back

22   Joseph Rowntree Foundation-A minimum income standard for Britain, July 2009. p24 Back

23   Joseph Rowntree Foundation-A minimum income standard for Britain, July 2009. p21 Back

24   ONS Statistics on Alcohol, England 2009, Table 2.12 Adults1 drinking in the last week, by usual gross weekly household income and gender, 20072,3 Back

25   Home Affairs Select Committee-Policing in the 21st Century, November 2008. p38 Back


 
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