Management and Administration of Contracted Employment Programmes - Work and Pensions Committee Contents


Memorandum submitted by The Department for Work and Pensions (DWP) (EP 14)

SUMMARY

    — This memorandum is provided by the Department for Work and Pensions (DWP or "the Department") as a contribution to the Work and Pensions Select Committee's inquiry into the management and administration of contracted employment programmes.

    — DWP spends around £1 billion a year on Contracted Employment Programmes. The Department manages the performance of providers and their contracts to ensure that public money is safeguarded and payments are only made for legitimate outcomes. Allegations of fraud or wrongdoing by providers are always investigated.

    — The Department is undertaking a major programme of work to strengthen its approach to performance management and provider assurance. Against a backdrop of significant rises in the number of people using Contracted Employment Programmes, enhanced measures, processes and systems are being introduced into all Contracted Employment Programme contracts over time through a revised contractual model, starting with Flexible New Deal in October 2009.

    — The Department is re-organising its contract management as part of a wider review of the way DWP commissions, sources, awards and monitors contracts. Its Commissioning Strategy, published in February 2008 sets out the Department's ambition to develop more strategic relationships with providers and to operate fewer, larger and longer contracts.

    — In September 2009 there were 374 providers running 849 contracts. This was down from 438 providers running 1,153 contracts in March 2009 and 2,058 contracts in January 2007.

1.  INTRODUCTION

  1.1  DWP spends around £1 billion a year on Contracted Employment Programmes (CEPs). Ensuring that this money is being spent effectively and appropriately to reduce costs and achieve value for money is at the heart of DWP's strategy for managing its providers and assuring payments made to them.

  1.2  The Department has always insisted on the highest standards of probity in relation to claims and payments for providers' activities and always investigates any allegation of fraud and wrongdoing.

  1.3  The Department is engaged in a major programme of change across all aspects of the CEP system which has required a strengthening of its approach to performance management and provider assurance.

  1.4  In 2007 the Department centralised the management and development of CEPs which had previously been operated as an adjunct to Jobcentre Plus' local activities. This structural move was made to create the conditions to drive through a more strategic and integrated approach to commissioning contracted employment provision.

  1.5  DWP published its Commissioning Strategy in February 20085.[52] It sets out how DWP plans to develop more strategic relationships with providers. As a result of this rationalisation and strengthening of the system DWP has streamlined the number of contracts it has, and the number of providers the Department contracts with at the top tier level. The Department is shifting from paying for inputs and process steps to paying for outcomes wherever appropriate, to achieve a step change in performance and quality.

  1.6  DWP's system for managing the performance of providers and their contracts to ensure that public money is safeguarded and payments are only made for legitimate outcomes has the following key features:

    — Contracting, to set performance targets and establish the framework of requirements on providers;

    — Controls and assurance, to check that providers are accurately recording and claiming for legitimate outcomes and that payments are being made accurately, and to assess the continued operation of controls;

    — Contract management; to keep providers to the highest standards of performance, quality and compliance, and to secure improvements where shortfalls are identified; and

    — Investigation of alleged or identified irregularities, in which the Department's Risk Assurance Division is a key player.

  1.7  DWP is strengthening its fraud prevention measures and its controls against fraud and error. This enhanced approach includes embedding the four key principles that DWP is in the process of applying to all its providers delivering CEPs:

    — There must be a "whistleblowers charter" in place, enabling supplier staff to report inappropriate behaviour by colleagues in respect of performance claims.

    — Performance management systems within the organisation must not generate perverse incentives among individual employees to falsely claim performance achievement.

    — There must be segregation of duties within the supplier's operations between those achieving performance and those reporting it to DWP: between claim and validation.

    — An internal audit regime must be in place which provides for periodic checks of the performance reporting regime.

  1.8  DWP is currently in a transitional period as it implements its programme of change. The Department expects the changes that it is making will enhance the way it manages its contracts to prevent fraud and error, ensure the highest levels of customer service, help more people into sustained jobs and safeguard public money.

2.  SAFEGUARDING AGAINST FRAUDULENT CLAIMS

  2.1  The Department has robust control and assurance arrangements in place to guard against fraudulent claims being made by providers. These include processes to validate payments, the assurance regime over providers' systems of internal control, and the wider control environment.

  2.2  Over the past year the Department has reviewed its strategy for preventing fraud, and the controls it has in place to protect against fraudulent claims. This is in response to the new challenges of assuring outcomes and payments in a changing environment. Providers are delivering higher value, longer contracts with less prescription. They are under increasing pressure to deliver performance against a backdrop of significant rises in the number of people using Contracted Employment Programmes (CEPs).

  2.3  DWP is in a transitional phase as it implements a programme of work to strengthen its fraud prevention measures and controls. Payment and performance policy and processes are being standardised and streamlined, more stringent fraud prevention measures are being introduced into CEP contracts, and the focus and remit of the assurance regime over providers is being broadened and strengthened.

  2.4  Many of the enhanced measures will be introduced through Flexible New Deal contracts, starting in October 2009. The Department is planning to apply the strengthened measures to all its CEP contracts with a value of £3,000 or more over time.

Checking and validation of payments

  2.5  Providers are required to submit claims for payment which are subject to validation by the Department. The claim form includes a declaration from the provider confirming that they are only claiming for payments to which they are entitled.

  2.6  CEPs have grown up over time, each successive programme having its own model for making payments and its own definitions of performance. DWP applies the same validation principles across all its provision, but the validation measures vary according to the type of provision and the funding model used.

  2.7  DWP has standardised the way it funds provision and the outcomes it pays for. The new standard funding model and outcome definitions are being applied to Flexible New Deal, and will be applied to new programmes going forward. There will however continue to be a range of different contract outcomes paid for across CEP contracts for the foreseeable future.

  2.8  The principle that DWP applies to validate payments is that the evidence must support the definition of the outcome being claimed. In some cases that means that job outcomes may be evidenced by way of a check (using our IT systems) to establish if the person for whom the outcome has been claimed has stopped claiming benefit—an off-benefit check. In other cases providers are required to supply the supporting evidence, either from the employer or the individual.

  2.9  If either the "off benefit" check fails or the evidence supplied by the provider is not satisfactory then the provider is asked to provide further evidence within a specified timescale. If further evidence cannot be provided the claim will not be paid or monies will be recovered as appropriate.

  2.10  The sample of outcome claims that are validated can range between 10% (where the provider supplies evidence from the employer/individual) up to 100% (where an off-benefit check is used as the supporting evidence).

  2.11  The Department recognises that improvements can always be made in its methods for providing evidence for outcomes. A review of its current arrangements is planned to start in late autumn 2009.

Assurance regime

  2.12  DWP has a robust system of controls and assurance in place to deter, prevent and detect fraud. These are in the process of being reviewed and strengthened as the Department responds to changes in its organisational structure and in the way it conducts business with providers.

  2.13  When the Department is letting contracts it seeks assurance from providers that they have policies and procedures in place to act as a deterrent to fraud across their organisation and sub-contractors.

  2.14  All CEP contracts have historically contained clauses requiring the provider to use their best endeavours to "safeguard the Authority's funding of the Programme(s) against fraud generally and, in particular, fraud on the part of the Provider's directors, employees or sub-contractors". CEP contracts also require providers to safeguard their systems against misleading claims for payment, and the provider is also required to notify DWP if they have reason to suspect that any serious irregularity or fraud has occurred or is occurring.

  2.15  DWP CEP contracts also contain a clause entitling the Department to terminate the contract in the event of any act of fraud committed by the provider.

  2.16  DWP has been reviewing its processes to prevent CEP provider fraud and is currently introducing more stringent and specific requirements for providers to demonstrate they have robust fraud prevention measures in place.

  2.17  From September 2009, all new CEP contracts, starting with Flexible New Deal Phase One, will specify that provider fraud prevention policies and procedures must satisfy the requirements of four key principles. DWP will also amend the bulk of its existing contracts to include the principles by November 2009. The principles are:

    — There must be a "whistleblowers" charter in place, enabling supplier staff to report inappropriate behaviour by colleagues in respect of performance claims.

    — Performance management systems within the organisation must not generate perverse incentives among individual employees to falsely claim performance achievement.

    — There must be segregation of duties within the supplier's operations between those achieving performance and those reporting it to DWP: between claim and validation.

    — An internal audit regime must be in place which provides for periodic checks of the performance reporting regime.

  2.18  DWP incorporated the four principles into the Flexible New Deal procurement undertaken earlier this year. Bidders were required to commit to set out their plans and systems for meeting DWP's fraud prevention principles. Any bidders failing to meet a minimum standard when detailing their plans were eliminated from the Flexible New Deal competition. These requirements will be included in all new CEP contracts over £3,000, starting with Flexible New Deal Phase One. DWP is amending its existing CEP contracts over £50,000 to include the four key principles from November 2009.

Assurance activity

  2.19  DWP is on the point of transition from old to new assurance arrangements.

  2.20  Until summer 2009 financial monitoring activity was undertaken through a risk-based regime of intelligence gathering and visits to providers to review the systems of internal control in place to manage the risks to DWP in relation to CEP expenditure. This included, amongst other key risk areas, reviewing the anti-fraud measures providers have in place and validation of payments.

  2.21  Based on their findings, the Financial Appraisal and Monitoring (FAM) team provided an overall view of the effectiveness of the provider's systems. Where perceived weaknesses were identified, these have been discussed with the provider and an action plan has been agreed to ensure that appropriate steps are put in place to make improvements.

  2.22  DWP has reviewed the role of FAM in recognition of the structural, organisational and strategic changes that have taken place since its inception 10 years ago. A Provider Assurance Function will replace FAM from October 2009; the role has been upgraded so that all team members will hold or be working towards a professional qualification. The new Provider Assurance Team will continue to review providers' systems through a programme of risk-based visits but the focus of this team has been broadened to include assuring value for money—not just payments. The Provider Assurance Team will therefore also assure the eligibility of self referred customers. Where customers are referred by Jobcentre Plus, their eligibility will be checked by Jobcentre Plus itself.

  2.23  The Provider Assurance Team will provide assurance that providers' fraud prevention systems adhere to the four key principles DWP is introducing into CEP contracts. DWP is also introducing a set of further checks into the payment and security processes. These include checking direct with employers and individuals in a significant sample of cases that job outcomes being claimed by providers have actually occurred.

  2.24  Risk Assurance Division undertakes investigations in response to allegations arising from DWP staff or third parties. It operates independently of those responsible for commissioning, controlling and accounting for the CEPs. Risk Assurance Division investigations staff are professionally qualified investigators who assess the quality of evidence in the allegation and investigate where there are sufficient grounds to proceed. This typically involves site visits, interviewing people (sometimes under caution) and examining evidence.

  2.25  Minor irregularities and findings of non-compliance are reported back to contract management and addressed internally. Where investigators suspect reasonable grounds that a serious criminal offence has been committed, Risk Assurance Division will refer the matter to the police, where there is sufficient evidence.

  2.26  Where it identifies any significant control issues relating to the Department's business and those with whom DWP contracts, it reports these to the Permanent Secretary and Departmental Audit Committee, a non-executive committee of the Department.

  2.27  During the period 1 April 2006 to 31 August 2009, 78 allegations have been subject to investigation by the Department. Of the 72 investigations that have completed:

    — in 14 cases the investigation discovered evidence that documentation included, or might include, deliberate false representations, typically in relation to client signatures or details of the service provided; and

    — in another 16 cases, irregularities were considered to be issues of contract compliance (eg invalid documentation to support claim or full conditions not met to warrant claim), with no clear intention of making an unwarranted gain or causing a loss to DWP.

  2.28  During the same period, five investigations undertaken by Risk Assurance Division have resulted in a referral to the police. In other cases where deliberate false representations were suspected, police referral was not considered appropriate because the amounts involved were low in value (ie typically less than £2,000) or no clear culprit could be identified.

  2.29  In the same period over 400,000 customers were helped into work through CEPs. In none of the cases investigated did the Department conclude that a provider was engaged in a systematic, organised policy of seeking to obtain invalid payments through fraud. Typically, in the few instances where it has been necessary to hold an investigation, Risk Assurance Division found a combination of illicit behaviour by individuals and inadequate management oversight and controls on the part of providers.

Wider control and assurance arrangements

  2.30  Other control mechanisms are in place to guard against fraudulent claims.

  2.31  The Department's pre-qualification and evaluation process stringently tests the suitability of bidders:

    — The Department will treat a bidder as ineligible to tender in cases where it becomes aware that they or their directors (or other person who has power of control) has been convicted of any of a range of specified offences including:

    — fraud;

    — corruption;

    — bribery; and

    — conspiracy.

    — The Department treats a bidder as ineligible to tender in cases where it is (or becomes) aware that any of a number of specified circumstances apply to the bidder, including:

    — criminal conviction relating to business conduct; and

    — grave misconduct in the course of his business.

  2.32  Contractual arrangements require the provider to have monitoring procedures in place to track the progress of participants. This tells them when they have entered into employment and if they have sustained this employment for the required period.

  2.33  Where DWP, either through the new spot checks, routine assurance visits or day to day contract management activities, suspect irregularities within the delivery of the contract it can use the expertise of Risk Assurance Division who are permitted immediate access to all records to undertake the necessary investigation.

  2.34  All cases of improper or fraudulent practice are taken seriously even if they only involve a single individual. In cases of organised fraud the Department would terminate a contract; however, DWP is committed to underlining with providers the seriousness of any instance of fraud. These include commitments to ask for a Board level response from the company, detailing the actions that they have taken, before considering the next steps.

  2.35  If DWP is misled and suffers loss, it will recover any amounts paid in respect of invalid claims made by the provider as well as damages that are appropriate. The Department will also seek clarification and assurances from the provider in respect of any disciplinary matters or procedural changes it deems appropriate. If the Department discovered that a provider was deliberately seeking to submit false claims with the knowledge and/or collusion of senior officers of the organisation the contract would be terminated immediately.

Improving management information

  2.36  The Department's approach toward monitoring provider performance is undergoing a fundamental change. In the past each programme has had its own definitions of performance and processes for collecting management information. The measurement of, and indeed the payment for, performance has rested on the SL2 data collection form (a carbon paper form with a high incidence of mis-recording).

  2.37  From October this year DWP is introducing a new Provider Referral and Payments system (PRaP), starting with Flexible New Deal. PRaP is an electronic, web-based system which will handle all transactions between Jobcentre Plus, providers and DWP to do with the referral and progression of customers and the payments providers receive for getting and keeping them in jobs.

  2.38  PRaP will provide the Department with fully up to date performance information across providers and programmes based on standard definitions of what is meant by "job outcome" and "sustained job outcome". PRaP is also key to embedding the highest standards of data security in our providers. PRaP will roll out to all DWP provision over time.

3.  WHISTLEBLOWERS: PROTECTING THE EMPLOYEES OF PROVIDERS

  3.1  DWP requires all Contracted Employment Programme (CEP) providers to demonstrate their commitment to prevent fraudulent activity and ensure integrity throughout the supply chain as a whole. These requirements are set out in DWP's four key principles, which will be included in all new CEP contracts over £3,000, starting with Flexible New Deal Phase One. DWP is amending its existing CEP contracts over £50,000 to include the four key principles from November 2009.

  3.2  The principles include a requirement for providers to have a "whistleblower" system in place to enable delivery staff to report inappropriate behaviour in respect of performance claims.

  3.3  The Department Provider Assurance Team will check for compliance with these requirements by asking the providers to complete a Provider Systems Questionnaire, and by gathering intelligence and findings from Departmental colleagues who have day to day dealings with providers. This will be followed up by a visit to the provider to confirm what they are telling DWP is right. During the visit the Provider Assurance Team look for evidence that the "whistleblower" system is in place, that staff know it exists and what to do in the event that they have concerns. Evidence is gathered through detailed process walkthroughs and testing. This can include talking to employees to establish their level of knowledge of relevant systems.

4.  DWP APPROACH TO CONTRACT MANAGEMENT

  4.1  DWP is engaged in a major programme of change across all aspects of the Contracted Employment Programme (CEP) system which has required a strengthening of its approach to performance management and provider assurance. The key principles of this programme are set out in the DWP Commissioning Strategy.

  4.2  DWP has re-organised its contract management structure and process. The re-organisation of DWP's contract management was part of a wider review of the way in which DWP commissions, sources, awards and monitor contracts. This review culminated in the publication of the Commissioning Strategy in February 2008. This strategy includes the ambition to operate fewer, larger and longer contracts. In September 2009 there were 374 providers running 849 contracts. This was down from 438 providers running 1,153 contracts in March 2009 and 2,058 contracts in January 2007.

The impact of the centralisation of contract management

  4.3  Central to the Commissioning Strategy is the ambition to develop more strategic relationships with providers. The Department will move away from a basic contract compliance model and into an approach where future thinking and insights from other delivery/management experience will be shared, with the aim of identifying opportunities for efficiency gains or better outcomes. DWP will be looking to providers to signal changes they are experiencing in customer characteristics so that the Department can factor that into policy development.

  4.4  It is that Commissioning Strategy vision that the Department has pursued through the centralisation of contract management and the strengthening of performance management and controls systems. Moving to having fewer, longer and larger contracts requires further shifts and a move to Supplier Relationship Management structures, with senior managers responsible for working with larger suppliers across a strategic and operational agenda, but backed up by close contract management at the point of delivery.

  4.5  In order to ensure that Jobcentre Plus was fully integrated into the new approach, during 2008-09 a New Ways of Working project, jointly led by Jobcentre Plus, DWP Delivery Directorate and DWP Commercial Directorate defined a standard operating model and clear roles and responsibilities for Jobcentre Plus' engagement with providers at District level. This work has now been handed over to Jobcentre Plus and local Provider Engagement Meetings are taking place.

  4.6  The main features of the Department's current active contract management model are:

    — active management of relationships with providers;

    — regular and frequent Provider Performance Review process; and

    — a clear disciplinary procedure for handling breaches of contract.

  4.7  At the hub of the relationship with providers are DWP Supplier Relationship Managers. They and their teams meet with providers regularly and frequently to review performance, contract by contract and the issues arising from that review process, as well as to discuss the performance and position of the provider as a whole.

  4.8  Provider Performance Reviews enable a comprehensive, formal on-site analysis of performance led by the Supplier Relationship Managers. They are completed within six months of the start of a new contract and, for existing contracts, on the basis of a risk assessment but as a minimum annually.

  4.9  Supplier Relationship Managers draw on a range of information. to inform the Provider Performance Review:

    — The achievement of key contractual performance metrics (typically job outcomes and sustained job outcomes).

    — The quality of provision, as assessed through inspection by Ofsted in England, Estyn in Wales and (from January 2010) Her Majesty's Inspector of Education in Scotland, and also through the DWP Quality Framework, which promotes the commitment to quality improvement through continuous self-assessment and development planning, culminating in an annual self-assessment Report.

    — The standards of compliance as assessed by the Financial Appraisal and Monitoring team (by the Provider Assurance Team from October 2009).

    — Intelligence received from Jobcentre Plus during regular Provider Engagement Meetings which bring together providers, contract managers and Jobcentre Plus at a District level.

  4.10  Following the Provider Performance Review the provider and Supplier Relationship Manager develop and agree a Provider Development Plan based on continuous improvement. The plan sets out next steps and review dates.

  4.11  For providers who are found to be unsatisfactory by Ofsted (or Estyn or HMIE) the Department contracts, via the Department for Business Innovation and Skills through the Learning and Skills Improvement Service, for support leading up to re-inspection. The Department also provides support for providers who are not unsatisfactory overall but who are found to have particular areas of weakness.

  4.12  DWP contracts include a "Provider Default" clause, which details the Department's approach to breach. Repeated or continual failure to meet performance target(s) constitutes a serious breach. In this case the Supplier Relationship Manager will serve a written termination notice on the provider giving sufficient detail of the breach. The provider and Supplier Relationship Manager will meet to agree how the breach will be remedied and detail this action within a contingency plan. If the provider fails to meet the action outlined within this plan the Contract Manager may serve 28 calendar days notice to terminate the programme/contract. During the course of the last six months DWP has taken action to terminate the poor performing elements of provision within CEP contracts in two instances.

  4.13  The Department is developing a new Star Ratings performance tool. Its purpose is to produce, for each programme, a forced ranking of provider job entry, quality and contract compliance performance every six months expressed in terms of the number of stars achieved.

  4.14  Star rating was developed with input from providers and is currently used in Employment Zones. Employment Zone Star Rating results are published every six months on the DWP website.[53] The Star Rating model will be applied in Flexible New Deal, where it will be used every six months to adjust market share between competing prime contractors. DWP expects Star Ratings to be a powerful driver of continuous performance improvement. Flexible New Deal Star Ratings will be in the public domain and published on the DWP website.

Contract management in the prime contractor model

  4.15  In the prime contractor model the Department holds the prime contractor to account for the delivery of performance and quality throughout its supply chain of partners and sub-contractors. The contracting process for new programmes requires bidders to provide detailed information about their delivery model and the contribution that each of their sub-contractors will make. These arrangements are transparent (details will be published on the DWP web site) and will be reviewed regularly as part of contract management, as described earlier.

  4.16  At the same time the Commissioning Strategy committed the Department to a market stewardship role: playing an active and transparent role to ensure that smaller, local providers, who have the capabilities needed and who perform well, can flourish and develop. A central part of this role is provided by the Code of Conduct which was published as part of the Commissioning Strategy and which forms part of contracts for new programmes starting with Flexible New Deal.

  4.17  The Code of Conduct states that the development of smaller sub contracted providers will be supported and encouraged by prime contractors and that they should provide a reasonable level of extra support for new entrants into the market. It also states that funding should be on a basis that is fair to the different organisations involved and reflect relative ability to bear particular risks. It was developed in consultation with officials from the Office for the Third Sector, and used the principles of the Compact's Procurement code,[54] and good practice from the Employment Related Services Association code of conduct.

  4.18  Prior to publication of the DWP Commissioning Strategy, there was no specific Code of Conduct in place to underpin and support sub contractors. Up until this point, supplier contract management provided the only route for any advice and support. Additionally, DWP is contracted directly with a significant number of providers who are less likely to have lengthy supply chains.

  4.19  Therefore as a consequence of the Commissioning Strategy's prime contractor approach, supply chain management and development has become more important, increasing the relevance of, and strengthening, the Code of Conduct. As a direct response to this, it was proposed that a two year pilot of a "Merlin Standard" should be developed to produce an industry supported accreditation process specifically designed to address the Code of Conduct, taking into account and dovetailing with existing standards and internal processes. In addition there should be an arbitration and mediation function to consider grievances which have failed to be resolved through normal dispute resolution processes.

  4.20  DWP will fund this pilot in the early days, moving towards an outcome of an independent and self-funding industry led accreditation and information service being in place by July 2011 (Merlin Standard).

  4.21  The Code of Conduct itself spelt out the key values and principles which DWP expects of providers and responsibilities of prime contractors. The development of a bespoke accreditation based standard—the Merlin Standard—will help embed these principals whilst at the same time provide an opportunity to drive innovation and best practice across the welfare to work market. An industry led Merlin Advisory Group will take responsibility for overseeing the development of the standard which will draw on existing continuous improvement approaches, standards and best practice used in the sector. In addition there will be an arbitration and mediation function which will consider grievances which have failed to be resolved through normal dispute resolution processes.

Customer Experience

  4.22  The Commissioning Strategy also sets out how the Department plans to ensure that the customer experience plays an increasingly important part in the commissioning of provision, how it is delivered and how it is improved. Jobcentre Plus continues to own the end-to-end journey for every customer throughout the life of a benefit claim and has the central role in assuring the quality of the customer experience. The Provider Engagement Meetings provide the forum for providers and Jobcentre Plus staff and managers locally to have regular dialogue at appropriate levels to ensure that problems are identified and acted upon.

  4.23  The DWP Customer Charter has been developed based on what customers have told the Department is important to them. It provides a high level commitment to the service standards that all customers can expect in all their dealings with the Department. Each area of the Department already has well documented service standards and these are being aligned with the new DWP Customer Charter headings of right treatment, right result, right time and easy access.

  4.24  In order to ensure that customers, Jobcentre Plus and providers know about their rights and responsibilities and what they can expect of employment programmes the Department is currently examining the processes, guidance and information issued when customers are referred to a provider.

  4.25  DWP is working on a joint initiative with the Employment Related Services Association to develop a statement of rights and responsibilities specifically aimed at customers using contracted employment provision. This will sit underneath the wider DWP Customer Charter. It will include details of the customer complaints procedure. DWP plans to launch this addition to the DWP Customer Charter in October 2009.

September 2009









52   Cm7330 published February 2008 Back

53   Star rating system is described at http://www.dwp.gov.uk/supplying-dwp/what-we-buy/welfare-to-work-services/star-rating-system/ Back

54   Compact Procurement Code is at http://www.thecompact.org.uk/shared_asp_files/GFSR.asp?NodeID=100698 Back


 
previous page contents next page

House of Commons home page Parliament home page House of Lords home page search page enquiries index

© Parliamentary copyright 2010
Prepared 18 March 2010