Horizon scanning
Throughout this section of Regulatory Radar we consider key changes and developments in the regulatory landscape, how these changes may impact businesses, and steps that businesses should consider taking
What is happening?The Financial Conduct Authority (FCA) has introduced an explicit “anti-greenwashing rule” to help prevent greenwashing and social washing in financial markets. The rule is part of a package of new measures announced by the FCA last November to improve trust and transparency of investment products.
On 31 May 2024, the FCA's new “anti-greenwashing rule” and accompanying guidance came into effect. The rule aims to protect UK customers from misleading or inaccurate information by ensuring that sustainability-related claims about financial products and services stand up to scrutiny.
The rule, which is contained in paragraph 4.3.1R of the FCA's ESG Sourcebook, applies to all FCA-authorised financial services firms and stipulates that any sustainability-related claims about a firm's products or services made available to UK customers must be fair, clear, not misleading, and consistent with the sustainability profile of the product or service. “Sustainability” claims are claims about the environmental and/or social characteristics of the product or service and could exist in many forms of communication, including but not limited to statements, assertions, strategies, targets, policies, information, and images.
Under the new rule and accompanying guidance, firms must ensure that all sustainability claims satisfy the four “Cs”.
Correct: capable of being substantiated.
Clear: presented in a way that can be understood.
Complete: they should not omit or hide important information and should consider the full life cycle of the product or service.
Comparisons to other products or services must be fair and meaningful.
Firms that fall foul of the new rule risk enforcement action by the FCA, including the imposition of fines for cases of serious misconduct under the FCA's existing powers.
The FCA's “anti-greenwashing rule” sits alongside, and is consistent with, other regulatory rules relating to sustainability claims in the UK, including the Competition and
Markets Authority's (CMA) Green Claims Code and the Advertising Standards Authority's (ASA) guidance on misleading environmental claims and social responsibility in advertising. All three take a principles-based approach and provide real-world, practical case studies to guide compliance. It remains to be seen whether the FCA will use the new rule to proactively investigate issues or sectors of concern across the market (as we have increasingly seen with the CMA and ASA) rather than waiting for third party complaints. Either way, tackling greenwashing is a stated priority for the FCA which is likely to want to land a "big name" to set an example for others in the market.
The rule is part of a wider legislative push, both in the UK and the EU, to enable investors and consumers to make informed decisions that are aligned with their sustainability preferences, and ultimately to drive capital allocation to more sustainable businesses.
Why does it matter?The FCA rule and guidance is indicative of an increasing regulatory focus on “greenwashing” and "social washing", where a business trades off perceived or advertised environmental or social credentials that are not actually reflected in the way the business or underlying product or service operates.
Alongside the market and regulatory considerations, business leaders need to be alive to the people implications of the rule, specifically how employees' concerns about sustainability claims (and any perceived delta with how the business actually operates) are dealt with. Whistleblowing, which has traditionally related to financial misconduct and safety, is now playing a pivotal role in ESG compliance and is increasingly used by employees as a tool to expose misleading corporate sustainability claims. For example, in 2022 Desiree Fixler, former Head of Sustainability at DWS bank (a subsidiary of Deutsche Bank AG), exposed greenwashing by the bank relating to statements it made about its ESG investment products. The allegations prompted an investigation by regulators in the US and Europe resulting in the bank being fined $19m, legal proceedings being issued by a German consumer group, the resignation of its CEO and significant reputational damage.
Legislators are also increasingly seeing whistleblowing as a key tool for ensuring compliance with the EU's flagship Corporate Sustainability Due Diligence Directive explicitly requiring in-scope firms to set up robust internal notification mechanisms and complaints procedures to surface any concerns about the firm's environmental and human rights impact. Whistleblowing is therefore both a vital tool for managing ESG compliance and helping to ensure concerns can be addressed quickly, but where internal whistleblowing processes are weak or employees' concerns are ignored, also presents significant reputational risk for businesses.
And with a recent uptick in shareholder and consumer group litigation against businesses accused of making misleading sustainability claims, firms that breach the FCA's new “anti-greenwashing rule” risk not only regulatory enforcement action by the FCA, but also potentially lengthy and expensive "follow on" litigation.
For more information listen to our Work Couch podcast episodes.
Whistleblowing series:
Part 1: A whistlestop tour of the law >>
Part 2: How to approach whistleblowing complaints >>
Part 3:Five key challenges for employers in 2024 >>
Social washing: avoiding the pitfalls >>
What actions should you take?Firms should review the FCA's new rule and guidance now and should be actively identifying which of their communications make reference to the sustainability characteristics of their products and services, whether these meet the threshold of being clear, fair and not misleading and, if they don't, the steps that will be taken to achieve compliance. Below we highlight some key “watchouts” from the FCA's guidance as well as lessons learned from parallel enforcement activity by the CMA and ASA.
Avoid broad claims like “sustainable” and “green” which are vague, unclear and are likely to be interpreted as meaning that the financial product or service helps create positive sustainability outcomes which is a high threshold and very difficult to substantiate. This kind of misleading impression may also be exacerbated by the use of colours, logos or visuals such as green or natural imagery.
Avoid cherry-picking information or only focusing on the positive sustainability elements of products and services, as this risks giving a misleading overall impression. The UK's consumer regulators are already proactively investigating these kinds of issues, with the ASA previously ruling that HSBC's positive statements about the support it provides to clients to transition to net zero was misleading as it omitted material information about the bank's ongoing financing of oil and gas production.
Take extra care where sustainability claims relate to “consumer-facing” products or services. Where applicable, firms must also comply with the Consumer Duty (Principle 12 and PRIN 2A) and should consider testing their communications through market research to check their claims are likely to be properly understood by consumers.
As the Fixler case demonstrates, businesses must also ensure that they have robust internal complaints and whistleblowing processes in place as one key piece in reducing the risks of greenwashing or social washing and ensuring a business can quickly rectify a misleading statement if it is identified. When RPC spoke to Sybille Raphael at whistleblowing charity Protect on The Work Couch podcast, she advised “The key way to ensure, and to demonstrate, ESG compliance is to prove that your staff are empowered to speak up. Whistleblowing is a key ingredient to any ESG obligation, to any ESG system really.”
Other practical measures include examining who is and who is not speaking up in your organisation; ensuring that whistleblowers are protected from victimisation for raising concerns by maintaining confidentiality; and offering them support for speaking up. Internal procedures must demonstrate a genuine and effective means of calling out misleading or inaccurate sustainability claims.
Kelly ThomsonPartner+44 7545 100420kelly.thomson@rpc.co.uk
Matthew GriffithPartner+44 7734 003788matthew.griffith@rpc.co.uk
Ellie GelderSenior Editor, Employment and equality+44 7517 830744ellie.gelder@rpc.co.uk
Sophie TusonSenior Associate, Environment and climate change practice lead+44 7712 511815sophie.tuson@rpc.co.uk
What is happening?On 18 December 2023, the UK Government announced the UK Carbon Border Adjustment Mechanism (CBAM), to be implemented by 2027. Details on the design and delivery of a UK CBAM are now subject to consultation. However, in the meantime, businesses would be wise to start preparing.
The UK Government is following in the footsteps of the European Union (EU), which aimed to address carbon leakage and support decarbonisation through its own Carbon Border Adjustment Mechanism (EU CBAM). The gradual phasing in period started on 1 October 2023 and the regulations are to be fully implemented by January 2026.
“Carbon leakage” is a phrase used to describe the risk that carbon costs could lead businesses to move their operations to countries with less stringent carbon pricing mechanisms. Currently, the EU CBAM targets six sectors which are considered to be carbon-intensive: cement, electricity, fertilisers, iron and steel, aluminium and hydrogen. The UK CBAM looks set to target all the same sectors except the electricity sector, and some other products which are not within scope of the EU CBAM.
Why does it matter?The amount of embedded emissions in the products that UK businesses import, export or sell in the UK will inevitably have an impact on the price of products and the ability of UK businesses to compete in the global market.
Affected industries are concerned that if the UK CBAM is not sufficiently aligned with the EU CBAM in terms of timing and interoperability, this could place UK businesses at a disadvantage. For example, the difference in the timelines for implementation of the EU and UK CBAMs may significantly disrupt supply chains, causing cheaper, high-emission products to be diverted to the UK.
Businesses are also discovering that working towards compliance with the EU CBAM is a major undertaking, requiring cooperation between different parts of a business and the collection of internal and external data, much of which has not been previously collected. Compliance with the UK CBAM is not likely to be any more straightforward.
What actions should you take?Now that the intention to implement a UK CBAM regime has been announced, it would be prudent for UK businesses to consider how they might be impacted by, and able to meet, future UK obligations, and to audit their current supply chains accordingly.
Another key consideration for UK businesses will be how to reduce those embedded emissions.
Businesses would be well advised to start the process of:
evaluating whether and how the UK CBAM is likely to affect their business
putting in place a compliance and impact mitigation plan
actioning an implementation process.
UK Government consultation closed: 13 June 2024
Proposed introduction of the UK CBAM: 1 January 2027
EU CBAM transitional phase: October 2023 to December 2025
EU CBAM full regime commencement: January 2026
Complexity
Cost of compliance
Pace of change
The volume of regulation
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Michelle SloanePartner+44 7545 100373michelle.sloane@rpc.co.uk
Keziah MastinAssociate+44 7546 760502keziah.mastin@rpc.co.uk
What is happening?The European Commission and the UK are preparing to implement a series of reforms to the EU Customs regime and UK customs procedures, respectively.
These reforms aim to streamline and digitise the customs and excise process and will impact retailers' customs obligations.
Why does it matter?A number of changes are due to come into force over the next 10-15 years in relation to the EU Customs regime. The European Commission will introduce a new EU Customs Data Hub (the Hub) which will provide customs authorities with real-time data in relation to supply chains and movement of goods. Through the Hub, businesses bringing goods into the EU will be able to log information about their products and supply chains and will only need to submit data once for multiple consignments, streamlining the process.
The information provided to the Hub will be used for EU and national risk analysis and, together with partner authorities, customs authorities will be able to intervene at any point on consignments depending on the risk analysis. The Hub is due to open in 2028 for e-commerce consignments, followed by other importers, on a voluntary basis only, from 1 January 2032. The Hub will become mandatory from 2038 onwards.
A new EU Customs Authority will operate from 1 January 2028, which will rely on data from the Hub to carry out EU risk management.
These changes are likely to have a significant impact on retailers who operate, or who have cross-border trade, in the EU as imports and exports will come under increased scrutiny.
The UK plans to implement a project called “Modernising Authorisations” which involves a single digital platform for all customs and excise information and aims to streamline and digitise the customs and excise authorisations processes. The new system will come into force on 30 September 2024.
In addition, the number of data fields that traders importing and exporting goods have to complete will be reduced by up to a quarter, thereby simplifying the customs declarations process.
It is to be hoped that these reforms to the UK customs procedure will reduce the burden on retailers importing and exporting products.
What actions should you take?Retailers operating in the EU should start their planning now to ensure that robust customs processes are in place in advance of the implementation of the Hub and the introduction of the new EU Customs Authority in 2028.
In particular, retailers will need to have systems in place that allow them to upload information about their products and supply chains to the Hub. Whilst this should reduce the administrative burden for retailers in the long term, it will be more important than ever to ensure the data is accurate. The new EU Customs Authority and partner agencies will have access to the Hub data in real-time, and it is anticipated that they will use that data to make decisions in respect of the customs liabilities of traders and associated enquiries and investigations.
The UK's “Modernising Authorisations” reforms are due to be rolled out on 30 September 2024, whilst EU reforms will be rolled out from 2028 onwards.
Daniel WilliamsAssociate+44 7541 683881daniel.williams@rpc.co.uk
“It is hoped that these reforms to the UK customs procedure will reduce the burden on retailers importing and exporting products.”
What is happening?From 22 September 2024 the funding regime for Defined Benefit (DB) Pension Schemes is going to change. The changes will affect how trustees and sponsoring employers approach DB scheme funding and deficit recovery plans. The changes will apply to all DB trust based occupational schemes, which forms the majority of DB schemes.
The Pensions Act 2021 introduced new requirements for trustees of DB pension schemes to set long-term funding and investment strategies for DB schemes. These requirements will be introduced from 22 September 2024 through the DB Funding and Investment Strategy Regulations. However, before the regulations can be implemented, the Pensions Regulator (TPR) will need to finalise its funding code of practice.
Trustees will need to work closely with sponsoring employers and actuaries to determine the long-term funding strategy and long-term investment strategy as well as establishing the funding journey plan.
Why does it matter?The new funding code goes further than the current regime, and expects trustees to establish a clear long-term funding strategy that will allow the scheme's assets to grow so that it will be able to be fully funded on a low dependency funding basis (ie the minimum funding level required) by the date the scheme's actuary estimates that the scheme will meet maturity. Additionally, there is an expectation that there will be a low dependency on the sponsoring employer by or before the maturity date.
The current funding requirements require schemes to have sufficient and appropriate assets to cover benefits valued on a technical provisions basis, which is the amount a scheme requires to provide for its liabilities as derived from an actuarial valuation.
When setting the funding journey, trustees will need to plan for how the scheme's funding will progress in accordance with its strategy as it moves towards its long-term funding target. This will require trustees to determine the levels of risk they consider are appropriate, which could include more aggressive investments, to achieve their ultimate funding objective.
The funding and investment strategy will require the sponsoring employer's approval and the trustees will then be obliged to explain the strategy further to the TPR as well as keeping abreast of how successfully it is being implemented. This process will also require consultation with the sponsoring employer. It will be essential that there are good communication channels and sharing of information between the trustees and the sponsoring employer, to ensure that the strategy can be agreed and monitored.
What to look out forTPR is currently collating the results of the consultation on how best to implement the forward-looking planning for trustees before publishing the funding code later this year. TPR has assured trustees that the funding code will not be released on the eve of the regulations coming into force, and that there will be a sufficient buffer to ensure that trustees are fully aware of what the expectations will be prior to the 22 September implementation.
What actions should you take?Trustees and sponsoring employers should start digesting the regulations now and seek legal and actuarial advice to ensure that they are in a good position to agree the funding strategy and journey. Trustees will also need to start considering the strength of the sponsoring employer's covenant as this will play a significant role in determining the most appropriate funding strategy and journey.
Rachael HealeyPartner+44 7545 100504rachael.healey@rpc.co.uk
Andrew OberholzerAssociate+44 7936 920516andrew.oberholzer@rpc.co.uk
“Trustees will need to work closely with sponsoring employers and actuaries to determine the long-term funding strategy and long-term investment strategy as well as establishing the funding journey plan.”
What is happening?Last year's landmark Economic Crime and Corporate Transparency Act 2023 (ECCTA) introduced a new corporate offence of “Failure to Prevent Fraud” (FTPF), whereby large companies can be held criminally liable for frauds committed by associated persons (including employees, subsidiaries and third party service providers) for their benefit. We discussed the scope of this new offence in detail in January's edition of Regulatory Radar.
The only defence available to a company charged with FTPF is to show that it had “reasonable procedures” in place to prevent fraud at the time the underlying offence occurred. The Home Office will soon be releasing its much anticipated official guidance on what constitutes reasonable procedures for the purposes of this defence.
However, in the meantime, companies can draw important lessons from the 2018 case of R v Skansen Interiors Limited, which to date is the
only time an equivalent defence has been pleaded in court. The defence was unsuccessful, shining light on what prosecuting authorities (and, ultimately, juries) will and will not regard as reasonable procedures in this context.
Why does it matter?While FTPF is a brand new criminal offence, the similar corporate offence of "Failure to Prevent Bribery" has been in place since the Bribery Act was passed in 2010.
As with FTPF, companies charged with this offence have a defence if they can show that they had "adequate procedures"[1] in place to prevent bribery at the time the underlying offending occurred. In practice, however, almost every company charged with Failure to Prevent Bribery to date has either settled outside of court or pled guilty at trial.
The only exception is small, London-based refurbishment contractor Skansen Interiors Limited (SIL).
[1] The difference between "adequate procedures" re: bribery prevention and "reasonable procedures" re: fraud prevention is largely semantic and not relevant for the purposes of this article.
When charged with failure to prevent the payment of bribes to win tenders in 2018, SIL denied the offence on the basis that it had in place adequate anti-bribery procedures for a company of its size and risk profile. SIL's defence rested on the following key points:
the company had adopted a range of different policies referencing the need to act in an ethical, open and honest manner. A separate, specific Anti-Bribery Policy was therefore not required
the company's employees testified it was common sense that they should not pay bribes and staff did not need a dedicated policy to tell them that
the company had implemented financial controls including checks on invoices to ensure their legitimacy before payment. These controls ultimately prevented the largest bribe from being paid.
On the other hand, the prosecution argued that SIL's procedures were not adequate for the purposes of the defence, on the basis that:
SIL had failed to review its anti-bribery compliance programme or take any other action in response to the passage of the Bribery Act in 2010
there was very little contemporaneous evidence of SIL taking any steps to promote a compliance culture within the business. In particular, while SIL had adopted various policies, there was no indication the company had taken steps to communicate those policies, provide related training or even ensure staff had actually read them
at the time of the offending, SIL had failed to designate anyone within the business with responsibility for ensuring its anti-bribery controls were embedded and complied with.
The jury in the case ultimately sided with the prosecution, finding that SIL's controls were not adequate for the purposes of a defence against Failure to Prevent Bribery and returning a guilty verdict.
What actions should you take?There are a number of lessons that companies can draw from R v Skansen Interiors Limited when considering how to implement "reasonable procedures to prevent fraud" for the purposes of ECCTA.
Perhaps the most immediate is to consider conducting some form of review into "outward facing" fraud risks and controls in response to ECCTA's passage. SIL was strongly criticised by the prosecution for not doing "anything at all" in reaction to the passage of the Bribery Act in 2010, which ultimately undermined SIL's claim to have adequate anti-bribery procedures in place for their business.
Companies should also consider how their anti-fraud policies are communicated across the business and whether they are doing enough to raise awareness of those policies and enforce them. The SIL case showed that juries are unlikely to accept the mere existence of relevant policies, or reliance on employees' common sense
understanding not to commit fraud, as sufficient evidence of reasonable anti-fraud procedures.
Thirdly, companies should consider clearly assigning responsibility for anti-fraud controls to someone suitably senior within the business. The prosecution pointed to the fact that nobody in SIL had designated responsibility for anti-bribery controls as evidence that the company was not taking its programme seriously.
Finally, companies should take steps to ensure that they clearly document and retain all records of ECCTA related reviews, discussions and decisions. SIL was substantially hobbled in its adequate procedures defence by the lack of contemporaneous written evidence that it was giving any thought at all to its anti-bribery controls. Ultimately, the jury interpreted this absence of evidence as evidence of absence.
ConclusionThe official Home Office guidance on reasonable procedures to prevent fraud will no doubt provide much greater detail on the different expected components of an anti-fraud programme.
However, R v Skansen Interiors Limited remains instructive on how prosecutors can undermine companies' appeals to the defence.
While waiting for the release of the official guidance, companies would therefore be well served to study the lessons of the past and avoid the mistaken assumptions that ultimately led to the first conviction at trial of a company for a "failure to prevent” offence.
Toby LamarqueManaging Consultant, Regulatory and Financial Crime+44 7864 248050toby.lamarque@rpc.co.uk
What is happening?The UK's Competition and Markets Authority (CMA) is increasingly focused on anti-competitive conduct in UK labour markets. The CMA considers well-functioning labour markets to benefit workers, businesses and the wider economy; and its focus is on deterring illegal cartel conduct which by its very nature is detrimental to creating well-functioning labour markets. This is part of a global trend of competition authorities scrutinising labour markets.
The CMA highlights costs to workers in its January 2024 report on competition and market power in UK labour markets. The report charts trends in UK labour market concentration and employer market power over the last 20 years. Concentrated labour markets lead to, on average, 10% lower wages for workers in the most concentrated 10% of labour markets, compared to the least concentrated 10%.
The CMA's 2023 guidance to employers identifies three main types of anti-competitive conduct in labour markets:
no-poach agreements, where businesses agree not to make any approach to, or hire, each other's staff, which can restrict the ability of employees to move to a competitor
wage-fixing, where businesses agree to fix employees' pay and/or other benefits. This reduces pressure on businesses to offer competitive remuneration or benefits
information sharing, where competing firms share confidential information about employees' pay and other terms and conditions.
The guidance also warns that this conduct can constitute cartel activity, and that there are potentially serious consequences for this illegal conduct, both for businesses and individuals.
The CMA already has two competition investigations underway in relation to UK labour markets. Both concern television producers and broadcasters, and practices relating to the employment of staff, as well as the purchase of services from freelance providers. It has also expanded the scope of its ongoing cartel investigation in the fragrances sector to cover suspected unlawful coordination involving reciprocal arrangements relating to the hiring or recruitment of staff involved in the supply of fragrances and/or fragrance ingredients.
In the CMA's 2024-2025 annual plan, there is a change of emphasis from identifying to tackling competition issues in UK labour markets, which suggests further enforcement could be on the cards.
Why does it matter?The CMA's focus mirrors the global trend of increased scrutiny of labour markets. Several competition authorities across the globe have intervened in relation to competition concerns in labour markets. For example:
in 2023, no-poach agreements came under the scrutiny of the French competition authority, the Autorité de la Concurrence. It targeted “highly-skilled” industries, including IT and engineering companies, who it accused of banning each other from soliciting and hiring their respective staff
also in 2023, the European Commission carried out unannounced inspections in the sector of online ordering and delivery of food, groceries, and other consumer goods, involving a suspected no-poach agreement
in May 2024, the European Commission issued its Competition Policy Brief on competition in labour markets. It refers to recent guidelines where the Commission has expressed its view that wage-fixing and no-poach agreements are likely to infringe Article 101 TFEU “by object”
the US Federal Trade Commission (FTC) announced in April 2024 a ban on new non-compete clauses, set to take effect in September, declaring it an unfair method of competition and therefore a violation of Section 5 of the FTC Act.
The increased scrutiny of competition in labour markets is an important shift in terms of competition law enforcement. This is a priority for many competition authorities across the globe.
What actions should you take?Potentially anti-competitive agreements can be written or take the form of informal arrangements. They may even amount to standard business practices in particular sectors. Organisations should be aware of the risk that certain arrangements, including no-poach agreements, wage-fixing and the sharing of competitively sensitive information, could involve very serious breaches of competition law.
Businesses must not agree with their competitors to fix wages/salaries and other employee benefits, and also must not agree to refrain from approaching or hiring each other's employees. Similarly, sensitive information about employment terms and conditions, including remuneration, must not be shared with, disclosed to, or received from, a competitor.
Tackling competition issues in UK labour markets continues to be a key focus area for CMA enforcement. Companies need to be aware of the increased competition compliance risks in relation to employment and HR practices.
These practices should be kept under regular review from a competition law compliance perspective, alongside business conduct more generally, to reduce the risk of inadvertent breaches. It is also a timely reminder for companies that regular competition compliance reviews are important.
“It is important to give recruitment staff compliance training on competition law and how it can apply in the recruitment process. The CMA advises employers to have solid internal reporting processes, and to ensure that staff are aware of them.”
Leonia ChesterfieldOf Counsel+44 7732 401765leonia.chesterfield@rpc.co.uk
Melanie MusgraveOf Counsel+44 7525 601312melanie.musgrave@rpc.co.uk
Tom ScanlonTrainee Solicitor+44 7523 678997tom.scanlon@rpc.co.uk
Mia PullaraTrainee Solicitor+44 7523 678940mia.pullara@rpc.co.uk
What is happening?The Information Commissioner's Office (ICO) have contacted 53 of 100 of the UK's top websites warning them to change their cookie banners to comply with data protection law, with a view to write to more. 38 of these websites have now changed their cookie banners with more aiming to comply soon or working on developing alternative solutions. To help these efforts they plan on developing an AI solution. This will identify the websites which have cookie banners which are non-complaint with current laws. "Our bots are coming after your bots" said John Edwards at a recent International Association of Privacy Professionals (IAPP) conference.
To help develop this solution, the ICO recently held a hackathon where ICO staff and external tech experts met to discuss how to regulate cookie compliance at scale and to develop a prototype to assess cookie banners and highlight breaches of law.
Why does it matter?Under Privacy and Electronic Communications Regulations (PECR), companies can be fined up to £500k for breaches of cookies rules. This may be increased to UK GDPR levels of fines in the Data Protection and Digital Information Bill (no.2) which is currently set as £17.5m, but the fate of the Bill is unclear after it was dropped in the pre-election wash-up period. Whilst it is unlikely fines will rise in value to meet the upper limits of UK GDPR fines, there may be an increased frequency of enforcement actions by the ICO given their new AI-assisted approach.
What actions should you take?The ICO has stressed that all companies should take action to ensure that their use of cookies and deployment of cookie banners comply with UK GDPR, PECR and ICO guidance. In particular, that the cookie banner implemented provides a "reject all cookies" option in its first layer.
Jon BartleyPartner+44 7912 242142jon.bartley@rpc.co.uk
Jermaine ScottPII Review Specialist+44 20 3060 6853jermaine.scott@rpc.co.uk
Kiran DhootAssociate+44 7749 045210preetkiran.dhoot@rpc.co.uk
