Written evidence submitted by the British
Bankers' Association
INTRODUCTION
1. The British Bankers' Association welcomes
the opportunity to give evidence to the inquiry by the Treasury
Committee into the Government's proposals for changing the framework
for UK financial regulation. We represent 220 banks from 60 countries
and have 40 associate firms within membership.
2. As the inquiry notice observes, the Financial
Services Authority (FSA) will cease to exist in its current form
and will be replaced by two new bodies—the Prudential Regulation
Authority (PRA), a new subsidiary of the Bank of England focusing
on the regulation of banks, deposit-takers and insurers; and the
Consumer and Markets Authority (CPMA), which will be responsible
for consumer protection and market conduct. A new Financial Policy
Committee (FPC) will also be made responsible for macro-prudential
policy and will sit alongside the Monetary Policy Committee (MPC)
within the Bank of England. Given the critical nature of these
changes it is right that the Treasury Committee has determined
that it should take an interest in their development from the
earliest possible stage.
3. We have little issue with the broad institutional
changes envisaged by the Government in that they:
— Create greater focus on the different
regulatory disciplines of prudential supervision and conduct of
business;
— Place within a single body—the
Bank of England—responsibility for macro-prudential supervision;
and
— Provide for better coordination between
macro and micro-prudential regulation through the establishment
of the FPC and the Bank of England's oversight of the PRA.
4. But we do believe that new institutional
structures bring a new set of challenges to be addressed and it
is not at all clear to us that the various issues raised by the
proposed arrangements have been as fully thought out as they need
to be. As matters stand, we see shortcomings in the democratic
accountability of the proposed bodies, their proposed objectives,
and the planned arrangements for due consultation process. We
believe that the importance of the involvement of the Treasury
may have been underplayed as a result of the falling away of the
Tripartite arrangements and can also see imbalances in the arrangements
for the PRA and CPMA. We are concerned in particular that insufficient
emphasis may have been placed on the need to maintain a coherent
markets division capable of representing the UK interest in European
and international fora.
THE BANKING
REFORM PROGRAMME
5. The Treasury paper (Cm 7874) opens by
explaining that there is an emerging consensus on the fundamental
cause of the crisis and we would not disagree with the key factors
identified: global economic imbalances; mispriced and misunderstood
risk; unsustainable funding and business models for banks; excessive
build up of debt across the financial system; and the growth of
an unregulated "shadow banking" system. We would add
monetary and fiscal policies to the list since the financial sector
cannot be said to be the main driver of economic cycles and we
would be missing a vital part of the picture if we were to overlook
this.
6. Some of these factors have been the subject
of the programme of banking reform begun by the then Financial
Stability Forum (now Board) and subsequently adopted by the G20.[14]
The reform of the regulatory and supervisory architecture undertaken
to date can be said to have focused on two overarching objectives:
reducing the probability and systemic impact of an institution
failing:
— Measures to increase the resilience of
the banking industry include banks holding more loss-absorbing
types of capital, increased capital requirements against the trading
book and putting in place better liquidity buffers. It also includes
improvements in corporate governance, risk management, supervision,
accounting, and product simplification, measures to reduce the
interconnectivity of institutions and the "recovery"
part of living wills; and
— Measures to reduce the potential impact
of a bank failure include the special resolution measures in The
Banking Act 2009, equivalent arrangements for investment banks
and the "resolution" part of living wills which will
help ensure that in the event of failure the authorities can act
swiftly and effectively.
7. Considerable progress has been made in
the delivery of the reforms needed to strengthen the financial
system. Banks are already holding more, better quality capital
and liquidity, international agreement has been reached on a new
capital and liquidity framework, and concrete steps are being
taken towards achieving a regime in which no institution need
be viewed as "too big to fail". This has been a collective
effort and the UK banking industry has engaged fully. Against
this backdrop it is difficult to see why the Government would
wish to build such a high degree of autocracy into the regulatory
framework.
STRUCTURAL WEAKNESS
IN THE
PROPOSED REGULATORY
ARRANGEMENTS
8. The changes proposed within the Treasury
paper relate specifically to the UK framework for financial regulation
and are intended to overcome identified weaknesses within the
tripartite regime. Whilst we would not disagree with the thesis
that these arrangements failed in important respects during the
early part of the crisis, so did those of many other countries.
We would also note that the individual authorities have each contributed
substantially to the banking reform programme and that many engaged
in this have brought an expertise that is widely respected.
9. In terms of the "twin peaks"
approach proposed within the Treasury paper, we can see ways in
which the model can be used to ensure that appropriate emphasis
is placed on both prudential supervision and conduct of business
and therefore have no objections in principle. The model can clearly
be made to work. But we have a number of fundamental concerns
with the arrangements as proposed in the consultation paper. These
are not inherent to the "twin peaks" model of regulation
and can be corrected providing the shortcomings are recognised
and there is a willingness on the part of the sponsoring authorities
to make substantial revisions to their proposals.
10. As matters stand, we see a democratic
deficit in the proposed structure, shortcomings in the proposed
objectives for the various authorities, including insufficient
alignment to the global and European environment, and the loss
of proper due consultative process in comparison to the FSMA regime.
We are also concerned about potential imbalances within the arrangements
for the PRA and CPMA. We comment on each of these before turning
to the specific questions raised by the committee.
INSUFFICIENT DEMOCRATIC
ACCOUNTABILITY
11. It needs to be appreciated that in proposing
the transfer of responsibility for prudential supervision to the
Bank of England, the Government is not simply advocating a return
to pre-1997 arrangements. At that time, the Bank was given independence
over monetary policy—a powerful economic tool—and
it has since been given responsibility for financial stability.
The Treasury paper builds on this by setting out potential macro-prudential
tools. This is in addition to the Bank becoming the lead authority
for crisis management since under the new arrangements it will
not only be the resolution authority, but responsible for the
triggering of any special resolution regime.
12. When you consider the breadth of the
Bank's new remit it is easy to see why many consider the proposed
accountability to Ministers and Parliament to be undemanding.
Accountability to Government Ministers for the activity of the
FPC appears to be limited to the Governor briefing the Chancellor
once every six months. Likewise, accountability to Parliament
will rest with the FPC producing a six-monthly report for submission
to the Treasury which will, in turn, lay copies before Parliament.
Only in the case of crisis management and a possible call on public
funds will the Governor be under an obligation to notify the Chancellor
in sufficient time to ensure that all options can be considered
and the Chancellor placed in a position to make the final decision
on the use of public funds.
13. Few would argue with the need for a
strong, independent central bank. In view of the broad responsibilities
now being assigned to the Bank, however, we would see a greater
need for a more interactive engagement between the Bank and the
Government and Parliament. The six monthly reporting arrangements
look lightweight. Whilst it may not be possible to develop the
type of quantitative proxy for financial stability that can be
set for monetary policy and the MPC, we would have thought that
the involvement of Treasury Ministers in the work of the FPC should
extend beyond the arrangements for the Chancellor to have the
opportunity to comment on the risks in the system and the action
being taken to address them. It is arguable, for instance, that
prior approval should be required for the exercise of macro-prudential
tools that may have significant socio-economic effect. We further
believe that in drawing up the detailed arrangements we should
foresee a need for a public debate about the significance that
macro-prudential tools may have for households and businesses.
SHORTCOMINGS IN
THE PROPOSED
OBJECTIVES
14. The proposed intention is that the FPC
and the authorities each be given a primary objective and for
other factors to be expressed as secondary objectives or factors.
While we can understand the need to give focus to each body, the
approach proposed looks to us to be a major failing since it effectively
detaches the respective bodies from responsibility for their actions.
The objectives of the FPC
15. If we take the FPC to begin with, paragraph
2.24 of the consultation paper proposes that its objective be
to protect financial stability by:
— Improving the resilience of the financial
system by identifying and addressing aggregate risks and vulnerabilities
across the system; and
— Enhancing macroeconomic stability by
addressing imbalances through the financial system eg by dampening
the credit cycle.
16. It is recognised, in paragraph 2.26,
that the use of certain macro-prudential tools "is likely
to affect the levels of lending to businesses and families and
the competitiveness and profitability of UK banks in relation
to foreign competitors". The paper goes so far as to say
that it will be important for the FPC to take factors such as
these into consideration when pursuing its primary objectives.
But the nearest we have to a commitment to the FPC being responsible
for the consequences of its actions is an undertaking that the
Government will consider whether the FPC "should be mindful"
of these and other secondary factors when determining a particular
course of action.
17. As discussed in the BBA's paper "A
Possible Macro-prudential Approach",[15]
the nature of financial stability is different to that of monetary
policy and so we would not envisage the success or otherwise of
the FPC being judged by reference to quantitative financial stability
targets. The objectives for the FPC will need to be couched in
much more general terms and its overall aim will be to ensure
that the banking industry is better prepared to weather economic
downturn. In the first instance, this will probably mean seeking
to reduce the amplitude of economic cycles rather than attempting
to prevent asset bubbles emerging, which may develop more over
time.
18. One concern is whether specific reference
needs to be made to the countervailing need to maintain economic
growth. The pursuit of financial stability, by definition, involves
constraining credit supply (and influencing demand) and there
is a risk that, if poorly calibrated, measures pursued could have
a disproportionate effect on economic growth. When combined with
the focused nature of the objectives of the Monetary Policy Committee
you can see that without some recognition of the benefits of economic
growth as the means by which businesses and families can prosper
then there is a real risk that the natural conservatism of the
central bank may result in a significant imbalance in the macroeconomic
management of the UK economy.
19. This therefore begs the question of
whether there will be the means by which consistency and inter-connectivity
between monetary, fiscal and financial policy can be achieved.
Previously, the Tripartite Standing Committee provided that forum
even if it appears that it was under-utilised in this regard.
Under the new framework, fiscal policy is put to one side and
the link between the MPC and FPC is embodied principally in the
Governor of the Bank of England, with the Treasury afforded no
formal role beyond "observer" status. It is difficult
to see where aspirations for economic growth fit within the arrangements
proposed.
20. Whilst we appreciate that international
discussions on the nature of macro-prudential regulation are still
at a relatively early stage, we believe that it would be helpful
for the FPC's objective(s) to be set into the context of the European
Systemic Risk Board and the way in which domestic measures would
fit within the European and international framework.
The objectives of the PRA
21. The setting of the primary objective
for the PRA is similarly misguided. Paragraph 3.5 of the consultation
paper proposes that the PRA has a primary objective to promote
the stable and prudent operation of the financial system through
the effective regulation of financial firms in a way which minimises
disruption caused by any firms which do fail. Factors which are
reduced to a status of something that the PRA must "have
regard" to include the principles of good regulation and
"important matters which relate to the public interest".
In fact, paragraph 3.10 goes as far as to say that the Government
is seeking views on whether the PRA need be troubled by secondary
considerations such as the importance of it using its resources
in the most efficient and economic way or the principle that a
burden imposed should be proportionate to the benefits which are
expected to result. We find it a matter of some considerable concern
that the question needs even be asked.
22. We further disagree with the conclusion
that the failure of "light touch" regulation necessarily
means that the prudential regulator should not be placed under
an objective to maintain international competitiveness. As far
as we are concerned, competitiveness is the lifeblood of the UK
financial services marketplace and respecting the need to maintain
a competitive edge provides a natural check and balance. Good
regulation, as measured by international competitiveness, provides
a counterbalance to ever increasing regulatory demands and encourages
the presence of the best global institutions in the UK marketplace.
It is difficult to see the justification for this being viewed
so negatively.
23. We are also concerned with the proposed
governance arrangements for the PRA. We are not convinced, for
example, that it necessarily achieves the right balance for the
PRA to be a subsidiary of the Bank and for the Governor to chair
the authority. It would be interesting to understand the extent
to which consideration was given to alternative arrangements,
for instance, relying more on the provision of powers to the FPC
to direct the PRA in the execution of macro-prudential tools.
This would have avoided what may be an undue concentration of
power within the hands of the Bank and permitted the specific
responsibilities of the PRA for the micro-prudential supervision
to have a clear identity without losing any of the benefits of
setting micro-prudential supervision within a broader macro-prudential
framework.
24. We would also question the proposition
that the non-executive directors of the PRA be stood down collectively
for decisions on significant regulatory or supervisory decisions
concerning individual firms. This to our mind creates a two-tier
board and results in a loss of perspective and experience that
would result from the involvement of the non-executives in such
decisions. Whilst, by definition, their involvement would involve
addressing potential conflicts of interest, it should be possible
to achieve this through a combination of the selection process
and the ability for non-executives to excuse themselves as necessary
from discussions.
The objectives of the CPMA
25. The same can also be said of the proposed
objectives for the CPMA. Its primary objective will be to ensure
confidence in financial services and markets, with a particular
focus on protecting consumers and ensuring market integrity. This
leaves the following expressed as secondary considerations, explicitly
referred to as "have regards" in chapter 4 of the consultation
paper:
— the principles of good regulation;
— the potential impact of policies or regulatory
decisions on consumer and business lending; and
— the need to maintain diversity in the
financial services sector.
26. We are concerned about the CPMA being
described as a consumer "champion". This, to our mind,
has the potential of creating an imbalance in its objectives from
the outset and also reinforces the concern that we have of the
CPMA somehow being detached from responsibility for its actions.
We would prefer therefore a description based more on the development
of a marketplace in which consumers are provided with clear and
understandable product information from which they can make informed
choices. This involves placing consumers in a position where they
can take responsibility for their financial decisions. The implication
that the new authority will somehow become their advocate does
not help this.
27. The objectives as expressed heighten
our concern about the lack of due process to be built into the
system. As far as we can see, the intention is that the bodies
be exempted from the usual standards of consultative due process
applicable to other arms of government and excused from any responsibility
of the consequences of their actions on the wider economy and
society.
28. We view the primary function of the
UK Listing Authority in a market regulation light given its responsibility
for overseeing consistency in disclosures and processes for listed
securities. As a result, we believe that the UKLA should remain
within the markets division of the CPMA as we see its function
as integral to the regulation of the markets on which securities
are admitted to trading. This would keep primary markets regulation
and secondary markets regulation in the same place and enable
a smoother transition to the new arrangements.
29. We see merit in the opportunity being
taken to place responsibility for consumer credit in one place
by transferring responsibility for regulated consumer credit from
the OFT to the CPMA.
INSUFFICIENT EMPHASIS
ON EUROPEAN
AND GLOBAL
INTERACTION
30. It is arguable that the objectives for
the key bodies, and potentially aspects of the reorganisation,
do not place sufficient emphasis on the inter-relationship between
the bodies and the European and global financial infrastructure.
In the case of the PRA and the markets division of the CMPA, large
parts of their activity are governed by European directives and
plans are in place for national rules to be superseded by mandatory
European rules. It is therefore essential that the authorities
give priority to representing the national interest in the relevant
European authorities and for their activities to be organised
in a way that creates natural "hubs" for the implementation
of the new European rulebooks. It is disappointing therefore to
see so little reference given to the European process in the Treasury
paper.
31. We believe, in particular, that there
would be merit in the responsibilities of the markets division
of the CPMA mirroring those of the European Securities and Markets
Authority (ESMA). For this reason, we would not view the potential
transfer of responsibility for the UK Listing Authority from markets
division to the Financial Reporting Council as being consistent
with the need to ensure that the authorities be placed in a good
position to represent the UK interest in European and international
fora.
32. It is also the case that the FPC will,
in some instances, need to take its lead from European and global
bodies—whether the European Systemic Risk Board, the Financial
Stability Board or the Basel Committee. Yet, again, there is scant
reference to the European and global context in which it will
work.
LOSS OF
DUE CONSULTATIVE
PROCESS
33. A great deal of time and care was taken
with FSMA to establish the right balance between providing the
prudential authority the scope to take necessary action to act
upon regulatory shortcomings and the need for appropriate due
process and consultation usually associated with changes to the
rule of law. These processes are essential to the maintenance
of market confidence in the regime in which financial institutions
operate and are the bedrock of the type of certainty that institutions
look for in determining where to locate business. This is as true
an expectation for a UK financial institution as it is for the
many overseas institutions that decide to locate financial services
operations in the UK.
34. It is also the case that there are many
instances in which consultation has proven an essential mechanism
for identifying major unforeseen consequences in planned regulatory
changes—a recent high profile example being the inadequate
nature of the creditor protections within the Special Resolution
Regime first proposed within the Banking Bill. It took a substantial
effort on the part of the banking industry and the legal profession
to persuade the tripartite authorities, including the Bank of
England, that there were seismic shortcomings in the proposed
arrangements. Due consultative process provided the time and opportunity
to make the case for strengthening the inadequate safeguards which
were maintained through many Parliamentary stages.[16]
35. In contrast, the Treasury paper makes
clear that the authorities need no longer be bound by a commitment
to due consultative process. Paragraph 3.22 in the chapter on
the PRA explains that the Government "is considering whether
the rule-making function should continue to be subject to statutory
processes, including consultation with a practitioner panel, wider
public consultation and the duty to carry out detailed cost-benefit
analysis prior to the introduction of any new rules"; paragraph
4.23 in the chapter on the CPMA observes that similar considerations
apply to the CPMA and, in addition, that the Government may enhance
the own initiative variation of permission powers for the CPMA.
SPECIFIC QUESTIONS
RAISED BY
THE COMMITTEE
36. We would comment as follows on the overall
issues raised by the committee:
Will the Government's financial regulation proposals
improve the framework for financial stability in the UK? Will
they work in a crisis?
We believe that the proposed structure can be
made to fit with the broader regulatory environment but see major
shortcomings in the arrangements proposed and believe that unless
corrected we could be preparing fertile ground for a future crisis.
Do the Government's proposals get the balance
right between tackling the problems of the last crisis and preparing
the UK financial system for the next one?
No. We believe that there are fundamental shortcomings
in the proposed arrangements and that these have the prospect
of building in structural weaknesses of a different, but equivalent,
nature to the identified failings in the current system that the
Government is seeking to address. As explained above, the new
arrangements are poorly defined in key respects and inexplicably
autocratic. We see this as a significant failing in the proposals
as set out so far.
How do the Government's proposals dovetail with
initiatives currently being undertaken at European and the global
level?
We believe that a major theme for the assignment
of responsibilities within the differing authorities should be
their need to represent the national interest in European and
global bodies. While recognised within the Treasury consultation
paper, we do not believe that this has been given sufficient emphasis.
This is evident in the order of priorities set out in the draft
objectives for each of the authorities.
What costs will the regulatory structure place
on consumers?
This depends upon the nature of the macro-prudential
tools handed to the FPC, the way in which the differing authorities
work together and the awareness on the part of both the PRA and
the CPMA of the extent to which their actions may change the supply
of financial services. Unless identified issues are addressed
we would consider there to be a significant risk of regulatory
action bringing about unforeseen consequences for the price and
availability of key financial services.
37. We would comment as follows in respect
of the questions asked on power, roles and responsibilities:
Do the Government's proposals appropriately assign
roles and responsibilities between the different regulatory institutions?
Whilst the roles would appear reasonably well
assigned, we fear that the proposed objectives will fail to instil
appropriate responsibilities.
Will there be unintended consequences of the Government's
proposals for regulation on the prospects for non-bank financial
institutions;
An unintended consequence of not achieving the
right balance in regulation, including the deployment of macro-prudential
tools in the regulated sector, may be flight to the unregulated
sector and less heavily regulated jurisdictions.
38. We would comment as follows on the questions
asked in respect of the Financial Policy Committee (FPC):
Should the FPC have a statutory remit? If so,
what should that remit be?
We believe that the remit should be qualitative
in nature and modest at inception; based on an objective to moderate
exuberance in economic boom years and enhance the resilience of
the banking sector to economic downturn. We would agree that there
is a need for this to be encapsulated in an appropriately defined
statutory remit and would argue that this should be premised upon
a need to balance financial stability with economic growth.
How should the success of the FPC, both in and
out of crisis, be measured?
Whilst the success of the FPC should primarily
be measured against criteria born out of financial stability,
such as dampening credit cycles and, at some future, stage, the
avoidance of asset bubbles, we believe recognition should also
be given to the generation of conditions suitable for sustainable
economic growth.
Given the international regulatory framework,
what macro-prudential tools should be granted to the FPC?
The FPC should take its lead from any directives
made by the European Financial Stability Board and others such
as the Financial Stability Board or the Basel Committee. Should
these advocate the adoption of clear, prescriptive macro-prudential
tools, such as the introduction of a counter-cyclical capital
buffer, then the FPC should act upon these without gold-plating.
In other instances it may be that the FPC should recommend for
Government consideration action based on the particular circumstances
of the UK market. This for instance could at some point include
measures aimed at addressing asset bubbles in particular sectors
of the property market, whether buy-to-let or commercial. In these
circumstances, however, it is unclear whether it would be for
the FPC to act or whether it would be more appropriate for the
committee to make observations which Treasury Ministers may wish
to pursue in devising public policy initiatives or in making adjustments
to government spending or fiscal policy.
Has enough been done to mitigate the risk of conflict
between the FPC and the Monetary Policy Committee (MPC)? Is the
FPC appropriately structured in terms of: the balance between
internal and external members; and the size of the Committee?
Whilst we support the creation of the FPC and
believe that the role it has to play is of the magnitude of the
MPC, we are not as yet convinced that sufficient thought has been
given to their interaction. This said, we believe that it would
be beneficial for the FPC to aspire to achieving an equivalent
status to the MPC and consider that the two committees should
be complementary.
A membership based on five executive members
and five non-executive members, plus the Governor of the Bank
of England as Chair, would not seem excessive. Of course, it would
mean that the FPC (in common with the MPC) will have "strong,
credible external representation" (paragraph 2.39), but this
will fall short of the expectation placed on UK corporates for
a majority of board members to be independent, including the chair,
and for this to be replicated for key board committees overseeing
executive performance.[17]
What characteristics, experience and qualities
should the Government look for when appointing external members
of the FPC?
While the FPC, as with any senior committee
or board, will benefit from diversity within its membership, core
characteristics must be independence of mind, financial experience
and socio-political awareness.
39. We would comment as follows on the Prudential
Regulation Authority (PRA)
Should the PRA be the lead authority over the
Consumer Protection and Markets Authority (CPMA)?
We would envisage that it is more the case that
the PRA should lead in respect of prudential supervision and the
CPMA in respect of consumer protection. Work should be undertaken
to avoid "underlaps" and an attempt should be made to
understand which will lead and in what instance in the case of
overlaps.
Is it appropriate for the PRA (and CPMA) to adopt
a judgements-based approach to financial regulation and supervision?
Yes. The adoption of judgement-based supervision
is about employing people of a caliber capable of questioning
institutions about their strategy, business models and culture.
This is more in keeping with the more macro-prudential view that
is being put in place and has to provide the supervisor with a
better means of understanding the real drivers of the business
than a tick box approach to a detailed rulebook.
40 We would comment as follows on the questions
concerning the Consumer Protection and Markets Authority (CPMA):
Do the reforms provide adequate protection for
the consumer?
One of the arguments in favour of a "twin
peaks' approach to regulation is that it allows regulatory responsibility
for consumer protection to come out of the shadow of prudential
supervision. Whilst we have no difficulty with this, we regard
early references to the CPMA being the consumers' champion"
as misguided. A more constructive positioning surely would be
for the regulator to work in favour of fair and reasonable outcomes
for consumers in which they take responsibility for the decisions
they take and in which financial institutions commit to providing
clear and understandable information on which to make those decisions.
To what extent will the regulatory and administrative
burden increase for those firms who now have to deal with two
regulators?
There will clearly be cost and bureaucracy involved
in having to deal with more than one regulator. The answer to
this, we believe, is early consultation on a memorandum of understanding
setting out the way in which the PRA and CPMA and others will
interrelate. There may also be a case for some form of common
services group to undertake such activities as licensing applications,
regulatory permission changes, regulatory information requests
and the collection of levies.
41. We would comment as follows on other
issues identified:
Should any of the proposed bodies be given responsibility
for promoting competition in the banking and financial services
sector?
We believe that the need is more for the authorities
to be given responsibility for maintaining a competitive marketplace.
This is sadly missing from the outline objectives set out in the
Treasury consultation paper. We do not see a competitiveness objective
as sitting on the opposite side of the scale to strong regulation
and instead believe that it creates an obligation on regulators
to consider the practical consequence of their actions. This is
relevant not only in a domestic environment, but within the context
of European negotiations where global imperatives are often seen
as secondary to regional considerations. We find it highly surprising
that the need for an international competitiveness test should
not be readily understood as being in the national interest.
Should any of the proposed bodies have a role
in promoting the City of London?
We do not believe that regulators should have
a promotional role as such. But we do believe that they should
have responsibility for the maintenance of a competitive marketplace.
22 September 2010
14 Financial Stability Forum Action Plan April 2008;
adopted by the G20 November 2008 Back
15
A Possible Macro-prudential Approach British Bankers' Association,
March 2010 Back
16
BBA Parliamentary brief-Banking Bill, second reading, October
2008 Back
17
The UK Corporate Governance Code, June 2010; Walker Review final
recommendations, November 2009. Back
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