Labour User Labour Provider group meeting 19 January 2023

Here you will find a recording of the webinar held on 19 January 2023 and associated presentations.

Webinar Transcript

Suzanne (Guest)32:42

You should know that the meeting is being recorded. Excuse me and we'll be shared after the event. Also, we have over 100 registered to attend this event and at the moment we are ensuring that when you join that your cameras are off and you're muted. If you want to ask a question and I would encourage you to ask a question, please use the chat function to do so.

Suzanne (Guest)33:11

I will then pick those questions up and ask the presenter to respond. We're going to try to answer as many of your questions as possible during this meeting. Throughout the session, we will be doing that.

Suzanne (Guest)33:29

I would ask because we do get lots of questions and as I said, I encourage that that if you do ask a question, you only need to ask it once. It will be picked up. You don't need to keep repeating it if we don't answer a question that you actually raise, we will come back to you after the session to give you an answer.

Suzanne (Guest)33:50

As far as we can, I also should mention that we have a feedback survey and we would like you to complete the survey because your feedback is really welcomed and appreciated. It's a very short survey. It helps us to understand our impact and improve our training and events such as this one. The survey link will be added to the chat shortly and I will remind you of this at the end of the meeting.

So without further ado for this webinar, I welcome all that have joined and our joining. I'd like to start with the GLAA update given by the CEO, Alicia. So if she could come on please and advise those attending what's happening at the GLAA.

Elysia McCaffrey34:40

Lovely. Thank you, Suzanne. I'm. I'm gonna start by wishing everybody a happy New Year. Because some people think it's too late to do that. I like to do it until the end of the month and it's the first time that I've seen you all this year. So happy New year. And I hope you all had a good festive break and there were five things that I wanted to talk about this morning and I'll be fairly brief to allow time for questions. And the first, I guess, to kind of set the scene is that there's a huge amount of change underway at the GLAA at the moment. We are going through a period of transition.How we work and we'll make a difference to how we work. And I think that you will start to see some of things these things too as you interact with us over the coming year. O the 1st that I wanted to draw your attention to is our strategy. We operate on a kind of three-year basis with our strategies and our current strategy is due to come to an end in a couple of months. So we've been spending lots of time with our board members working through what should our priorities be. What do we really want to achieve over the next three years and how do we organise ourselves around that.

Looking at how we grow, what we've learned, what we need to be doing, and how we should be really spending our time and there's no secret that across governments, across government departments, there's not a huge amount of money at the moment. So what we're really thinking about in GLAA is how do we make sure that we're using every bit of funding that we receive to have the biggest possible impact that we can 4 vulnerable and exploited people. And so in line with that, there are a number of key bits of work that we've got running at the moment that are are making a real difference to.

How we work and we'll make a difference to how we work. And I think that you will start to see some of things these things too as you interact with us over the coming year. O the 1st that I wanted to draw your attention to is our strategy. We operate on a kind of three-year basis with our strategies and our current strategy is due to come to an end in a couple of months. So we've been spending lots of time with our board members working through what should our priorities be. What do we really want to achieve over the next three years and how do we organise ourselves around that.

Elysia McCaffrey36:14

And I'm not ready to share with you at the contents of that strategy because we haven't, we haven't quite got that signed off. That's going to be next month that we sign it off internally and then we'll share it with the Home Office for Ministers to sign off. And what I will say is I think we'll probably bring something to you at the next one of these meetings if Suzanne is happy with that, to talk to you about what our new strategic priorities are and what you can expect to see from us in how we're working. So we are very excited about that. It's very ambitious and it's very stretching and we think we'll enable us to do the best job that we can for, for workers.

Elysia McCaffrey36:48

And then underpinning that, we are working on a new target operating model for the organization. So again, just making sure that there is efficient as we can be, we're improving in the best ways that we can. We're looking at what the landscape says, what are the changes in government policy, what are the changes in like the nationalities of workers and the way people are working so that we can make sure that we're doing the best that we can. So those are two kind of big set piece things which are very internal to us in some ways. But I think we'll change the way that we work and change the way that we work with you.

And then there were just three things I wanted to draw out on kind of specifics of things that we're thinking about at the moment and things that are happening in the GLAA. So the first of those is around our level one award in workers rights. So I'm hoping that you do all know something about this, but for those who don't, we worked and a couple of years ago now actually with the skills and education group to develop a Level 1 qualification in workers rights. So this is part of our prevent strategy and it's thinking about how do we really make sure that workers are empowered and they know what their rights are and they're able to.

Elysia McCaffrey37:54

Be supported in the right way when they're at work.

We've had really good success with this award. It's been rolled out in, in really kind of Umm, innovative and productive ways. We've been really pleased with that. But we have had some feedback that perhaps if your academic level isn't very high, if you have sort of accessibility needs and so on that the qualification isn't quite as accessible as it could be. So we've learned from that and we're doing some work at the moment in particular with the Romanian Embassy actually to convert to the qualification into more of a course.

Elysia McCaffrey38:27

Uh to translate it into Romanian, really, with a view to making sure that it's as accessible as it can be for as many people who need to access this.

So a lot of the workers that we work with in the UK are from Romania, so we're hoping that this will have a really big impact. We'll evaluate this and then we'll look at whether we need to then translate into other languages and train trainers and other languages to deliver this training. So we're really pleased with that. And as a key piece of work that we're looking at at the moment.

Elysia McCaffrey38:55

The the second thing I wanted to mention, and I'm not going to say too much about this because the team are going to discuss this in this meeting today is around our new control strategy. So one of the things that we read need to be really mindful of because you know we are a small organisation, we only have 120 people and we don't have a big budget. We need to make sure that we're always targeting our resources and our efforts in the right way and the control strategy that you're going to hear about today. Signals are changing how we're working and how we're making sure we're really prioritising in those right areas.

But I don't want to give any spoilers on that because colleagues have come to talk about that today as well, and I think the final thing that I just wanted to draw out actually is how proud I am of some of the work that our regulation team have been doing over the last month and in particular that we have suspended a licence and because of an organization charging work, finding fees, which of course is not OK and we're pleased that we've been able to make that suspension. And this is what we're here to do. You know, we're not just here to give licenses, but also to make sure that.

Elysia McCaffrey39:57

The people are doing the right things by their workers and also over the last month we've had 10s of thousands of pounds of holiday pay has been recovered and that should have been paid to workers and wasn't. And these are just a couple of examples of the things that I'm really proud of that are really tangible and make a difference in the lives of the people that we're we're here to work with and we're here to serve. So I think, Suzanne, I think I'll pause there. Those are the main things I wanted to cover. Really happy to take any questions on any of those points. But I think that some of these things will be follow up following up on in more detail.

Elysia McCaffrey 40:29

For all of our, our attendees are really soon.

Suzanne

Well, thank you for that. We don't yet have any questions for you, but you're not going, are you? You stay for the webinar, so there may be questions that come up later that you together with one of the presenters, might want to respond to. And I'll keep an eye on the chat if I can remind people. If you do want to ask questions at any time, please put it in the chat and then I will advise whoever it should be dressed to what that question is. So thank you, Alicia, for the moment. I think we'll move on swiftly to talk about the control strategy which you teased us with.

Elysia McCaffrey40:37

I'm not no Halo warning.

Thank you.

Suzanne (Guest)41:07

And I'm going to start off with Donna, who's going to, I believe, Donna, you're going to give a an overview and then we're going to have Jen come on afterwards and followed by other members of the team. So, Donna, I'm leaving it to you to take us forward.

Donna Duffy41:22

Thanks, Suzanne. Morning, everyone. As Suzanne said, I'm Donna and I'm the GLAA strategic and senior intelligence analyst and I'm here today to give a short presentation to explain what the control strategy is.

Donna Duffy41:34

How will you use it and what we hope to achieve and to introduce the current priority areas and then the planners will give you an introduction over their plan areas.

Though the control strategy sets both strategic and operational priorities for the GLAA.

And this is informed by our strategic threat assessment, which reports on both current and long term issues affecting our organisation or likely to affect the GLAA in the coming months. So, for example, in the current strategy, we've looked at things like the labour supply shortage, the cost of living crisis and the nationality and borders bill, which may impact on our priority areas and areas of risk and harm going forward.

Donna Duffy42:18

It's important that strategic assessment is a living document, so it needs to be current and relevant to be effective, and the analysts will continually examine the key threats against our strategic priorities to ensure we can deliver an efficient and robust service.

So the assessment will look at emerging issues and emerging areas of risk and harm, which cover political, economic, social, technological, environmental, legal, organizational and media factors.

And it will also analyse incidences of labour exploitation on licensed gangmaster in non compliance of licensed gangmasters and labour market offences, including forced and compulsory labour.

Donna Duffy43:02

The emerging issues we identify will be risk assessed using a law enforcement risk assessment called morale.

If there was emerging issues are deemed of a higher risk than the current control strategy priorities, they'll be presented to the strategic tasking and Coordination Group which is made-up of the senior leadership team, who can then amend the control strategy. So the important thing here is that it's not set in stone and it can change and be dynamic dependent on where the risk is at any particular time.

Donna Duffy43:34

Risk assessments will also identify where we have reduced the threat in a particular area and then maybe able to be removed from the control strategy again by the strategic tasking group, the senior leadership team.

The assessment will also identify gaps in the intelligence picture. So, for example, at the moment there's a gap around how workers are recruited. Is it word of mouth? Social media and perspectives? Outside of those, we regulate and license whether a recruitment agency is involved and whether this differs in different sectors where there's a certain type of recruitment method in a certain sector and whether that differs between nationalities as well. So these gaps are shared within the organization and they should be on the mind of investigators. Regional field intelligence officers when they're out and about on the in the field.

Donna Duffy44:19

We also share with partner agencies. We've also shared tried to share with the voluntary sector the third sector as exploited workers, maybe more willing to share their experiences with charities and and that's sort of those sort of organisations.

Can I have the next slide please?

So in essence, the control strategy ensures those areas of greatest risk threatened harm to the GLAA are prioritized. This allows a consistent approach across the organization and gives an insight as to where more resources are needed.

Resources can be requested via our tasking and coordination meetings, and there can also be request for resources outside of the control strategy where appropriate and relevant.

And it's important to note we will still have our business as usual, for example, application inspections.

Donna Duffy45:09

Next slide please.

Katherine.

So currently we've identified 4 priority areas and these are harm and exploitation of shellfish gatherers forced a couples to be labour in areas deemed as high priority. Currently agriculture, residential care homes and hand car washes, exploitation of workers under the seasonal workers scheme and umbrella companies both exploiting workers and operating without a license.

Plant owners have been identified for each priority area and they will now talk you through what that means. Thank you and I'll. I'm here for the whole morning. So if you have any questions, I'll be around to pick those up later.

Suzanne (Guest)45:48

I should have advise those on the webinar what we're going to do is now take those four apart being presented by individuals and we will take questions after each of those sections and then if you have more questions then all five of those, Donna Serena Martins and Jen will stay on to answer any questions that you might have after the you've heard all of the presentations. So I think, Jen, you're coming up next to talk about high priority sectors.

Jennifer Baines46:18

Good morning everybody. I'm firstly an apology. I'm not on screen this morning because my Internet connectivity is a bit hit and miss, though I think you'd probably prefer to hear me rather than see me, which is a popular opinion amongst my colleagues if I'm honest.

I'm so I'm here to speak to you about the forced and compulsory labour in high priority sectors and I am one of the STI's in the.

Suzanne (Guest)46:44

Could I hold you on for a moment, Jennifer, I'm not sure what I'm seeing are a number of people on screen as round dots. This the slide is very much down at the bottom, is I? I'm just want to make sure that those on the webinar can see your slide rather than the names of various people on screen. Katherine, can you tell me that?

Or Megan.

Elysia McCaffrey47:06

I can see it properly, Suzanne.

Suzanne (Guest)47:08

That's all I wanted to check. Thank you very much. Sorry, Jen. Please continue.

Jennifer Baines47:12

No, that's great. Thank you very much. So my name's Jen and I am the SIO in the southeast for enforcement purposes and and what that means is that one of my largest responsibilities is to be really aware of what's happening across the UK and across the South East and reacting to those emerging trends and threats with with new strategies and new ways of dealing with that. So could I have the next slide, please? Megan, thank you. So today, I'm going to speak to you about agriculture.

Jennifer Baines47:44

And car washes and care homes. Now, these are all topics that I am extremely passionate about. So I apologize again if I rattle on too much and they are really, really important sectors and I will pick apart each of these sectors and explain to you how we've got to the point that these are now considered are high priority sectors.

I'm.

I will begin with with agriculture and you might have noticed that some of these are regulated sectors and some of these are not regulated sectors, but there is a.

Jennifer Baines48:19

Reason behind that which I will explain to you. So firstly if we if we speak about agriculture, why agriculture, well as a lot of you will know as labour users and labour providers across the UK, agriculture is one of the largest trades in the UK. We are the Garden of England in the South East and we have a lots of agricultural work and a lot of low skilled workers are in this sector.

Jennifer Baines48:50

They're agriculture work includes working with all livestock, dairy farming, growing, harvesting, produce and so on. So it's quite a large sector in court, including the horticultural sector. There's quite a large crossover in agricultural sector between unlicenced trading. So that's.

And you section 12, section 13 issues and offences whereby people are supplied and used by unlicensed gangmasters but additionally.

One is the very very important reasons around agriculture is that we see more and more elements, that of exploitation on the under the modern slavery Act, so that can be things like terrible accommodation, lack of pay, lack of proper equipment, lack of PPE, UM, bad health and safety practice.

And one of the biggest problems around that is that these things aren't as easily visible as other sectors because the general public don't generally walk onto fields and farms. And so it becomes quite difficult to detect.

Uhm, what happens with regards to increasing the risk over the last couple of years and where we've done a lot of work during COVID and and and after COVID lockdowns trying to work out the levels of risk and how that landscape has changed and what we have seen across the last couple of years is that there's been an increase of work finding fees as an easier earlier mentioned, there's been an increase around the section 12 section 13 offences.

Jennifer Baines50:28

With regards to supply of gangmasters, there have been issues around supply from from different countries and and the way in which people have arrived in the UK.

Obviously there have been struggles around uh people's right to work in the UK.

And whether or not they are, they're working legally for an employer.

I'm.

This means that what we've seen is quite a large change in what we're getting told about and how we're dealing with that. And finally, you know with the highest risk.

We've got, yeah. Somebody's just recognized seasonal worker issues. Yeah, that that will be explained a little bit further on.

And you know, these things have changed over the last couple of years and that means that the risk is changing as well and we have to really, really recognise what's happening and how we can react to that. And one of our biggest problems is the larger recruitment fees being charged. Often that can be before they come to the UK. So for example, I know a lot of you on this call. I'll have spoken to about in the last couple of years the the fees that are being charged, for example, recruitment in Romania.

And people are being charged hundreds of pounds to fill out application forms.

In effect, often they can be in debt ******* before they even reach the UK, which starts that cycle of slavery and exploitation before they reach the UK. Especially uh, when they're being told that they're coming to one company, so they're going to work for a large labour provider, and when they come to the UK, the story that they've been provided is not necessarily accurate.

Next slide please, Megan.

OK, So what are we doing and how do we work with partners to tackle to tackle the threats and trends across the agricultural sectors? Well, one of the most important partners that we have across the agricultural sector is you. So the labour providers and the Labour users are our most important partner alongside law enforcement. So that means the partners that we work with in order to enforce these activities, for example the police.

HTML they health and safety, immigration, local authorities and deferral. So what we try and do is work really, really closely with our labour providers and our Labour users to make sure that we are aware of issues and I see a few of you on calls that I've spoken to very recently where you've identified a potential issue within your labour and.

What is extremely positive about a lot of the Labour users and providers across the UK are licence people is that you will come to us and you will stay with with there's a problem. We're worried about this. What should we do and we will work with you in order to determine what that problem is and how we can resolve it.

That's very positive for me because that.

Often means the I don't have to take enforcement activity and prosecution activity. It means that we can work together to resolve issues that are minor without disruptions to licence holders and disruptions to like to the Labour users, that means that obviously.

And we continue to allow the supply chains in the UK to operate freely, which is obviously very important.

Jennifer Baines54:11

So how do we do that? Obviously, we educate people, we spend a lot of time educating workers across the UK. We've done a lot of joint work with labour providers and labour users open days where we've been available on site for people's come and talk to us and and we've provided advice in different languages.

Different ways of providing advice, for example.

And there are there are ways in which you can nowadays you don't even have to. It doesn't have to say GLAA over it. And we can often, you know, startle posters and things like that to give everybody the opportunity that if they've got a problem, they know how to report those problems to us, which is obviously really positive and and that's what we need. We need people to talk to us and tell us what the problems are in order to be able to react to them and for us to use the appropriate tools to react.

OK, so currently the risk that we're seeing, I I do know that there are questions that aside, but I will ignore those for the time being. So I'm not ignoring them. I will. We'll get to them eventually. And the current ring.

Suzanne (Guest)55:31

Can I give you the questions when they when you finish your talk?

Jennifer Baines55:35

OK, fantastic. So the current risk, obviously the risk is high, these are high priority ultimately current risks.

With regards to my exploitation or obviously the worst case scenario when somebody is in slavery and they're being exploited, they're being coerced, they're being controlled, they're in debt *******, they've lost their passport, they're identity. They're not free to come and go. They don't have access to their own money. They are, as it says, they are in in slavery. That is the highest list of people that can result in death or injury. Terrible accommodation. I've recently had workers with frostbite living in.

Jennifer Baines56:20

Unheated caravans without any water. I'm glad to say that's extremely rare, certainly amongst our licensed gangmasters.

And and unfortunately, as I anyone that's ever heard me deliver to you, I will always say it's very easy to go and buy drugs and sell them in the UK to different people. But the problem with that is that once they've sold, that's it. If you have a worker that you can put to work and you can exploit every single day, you can do that with 10 workers. And if you can do that with 10 workers, you've got that income until you sell that worker or until they die or until they escape.

So what we want to do is make sure that we are recognising when these issues occur and we're reacting to them.

From a financial perspective to the UK, there's lots of revenue to UK and economy when when people are perhaps working illegally or working without paying the correct taxes. National Insurance, which all has impact on both the UK economy and the workers themselves, because that has consequences with regards to what they're able to access in the UK.

They're what tools do we have currently in the agricultural sector? Well, obviously our biggest tool and our most successful one is the licensing scheme and the backup of the licensing scheme around compliance and regulation and checks that we do with regards to visits, though obviously that is something that's really, really important to ensure that our licensees are operating correctly and our life, our Labour users, our using that labour appropriately.

And we do take offense action against unlicensed gang mastering, and we do look to prosecute under the Modern Slavery Act when we're able to meet that threshold. If we're unable to meet that threshold, we do have other tools that we put in place when we can from issuing warning notices, issuing advice notices, revisiting and speaking to people again and seeing whether or not they've been any improvement around that. And in addition to that, we.

Ohh, currently in the UK the GLAA or the top user of slavery and trafficking risk orders, which means what we can do is present information to a core that says actually we're really not happy about this situation. We haven't met the threshold to prosecute this person, but if no intervention is made then what might happen is that these people will exploit their workers further and this could lead to slavery and trafficking.

So that's about it. On the agricultural sector, and if you're not sick of my voice already, I will also speak to you about the car wash next at an extremely briefly the care sector.

I'm.

Hand car washes or yes.

The Imagine being trapped in a employment that you don't know if you're gonna get paid, you don't have any access to that money. You are subject to threats about your family back home, who you're trying to support, and you can't go and ask anyone for help, because if you do, you might be treated as as a a criminal yourself. So it's it's really hard situation. And what do we do?

Jennifer Baines1:09:16

Currently, to try and educate people around that go back, go back. Thank you.

I'm we we currently work a lot with public again, it's very similar these things. So we do a lot with regards to Carl, which is is we do to agriculture and we speak to as many people as we can. We educate as many people as we can. We work really closely with everybody that will work with this to spread awareness of that. And I will tell people lots about the responsible car wash scheme, about the safe Car Wash app, about our reporting methods.

What people can do, and you know about taking responsibility yourselves if you go to a car wash and you spend £5 on a car wash, then you have to ask yourself.

Is that value for money? And and I'm I spending £5 here whereas actually I should be spending a little bit more and all these workers getting treated properly. So you're £5 bargain might mean that carrel, for example, doesn't have any heating or hot water. Is it worth it? I'd like people to to start asking those questions themselves. Next slide please, Megan.

OK.

Will stop talking shortly and an address. The questions in the side. So again risk, what risk does this pose to the public and to work as well ultimately death? You know, there have been serious injuries at Carwashes. They are on industrial sites, people are working with chemicals, vehicles and.

It's very dangerous, uh.

Ice Age's organized criminal gangs operating uh through hand car washes to still his height multiple offences now.

A lot of time, criminality goes hand in hand, the offences go hands in hands. They once you've, you're a criminal, often fingers and pies. If you're trafficking people, you're taking advantage of people with regards to labour, you're exploiting people.

There might be elements of of other criminality as well, so it's it's quite in depth and.

It's definitely something that we need to work with other people in order to get a grip on and in addition to that, workers can be forced into criminality. So, for example, at this time of the year, it's really cold. People aren't necessarily getting their their cars washed, workers won't be getting paid.

Anything often and you know the hours the car washes are open at bit, hit and miss. People are starting early, it gets dark early. So what that often means is that workers then can be forced into other types of criminality. So for example, county lines.

This is obviously something else that provides extra risk to those workers, an extra risk to the public. Uh, last UK economy from a financial perspective, I wouldn't like to guess the amount, but if you consider the thousands of car washes in the UK and the potential loss with regards to revenue and lack of tax payments and so on.

And it could be a significant it. Well, it it is a significant amount of money.

I'm.

We work with all the agencies, everybody that we can possibly work with. We will take along as mentioned previously, there's a little list there for you.

You will notice National Crime Agency on that list now the NCAA that we work with very regularly depict the the story in the UK and the high risk that we will. We will sell this to them as high priority and we want the NCA to recognise that through our intensification periods and operation aid. And I'm really, really pleased to say that they have done and we are now working nationally as as a high priority with regards to car washes.

So what tools do we have? Well, it's really tricky at the moment. We are not. The car washes are not part of the regulated sector.

Our hands are quite tired when it comes to modern slavery offences because it's very rare that we can meet this threshold around the coercion and control, because there's sometimes elements of collusion around this as well. So what we tend to do is highlight those issues and work out where that exploitative activity is and we work by visiting, giving advice, seeing where everyone, not people, are improving their practices.

And then if we're not seeing any improvement, what we're doing is we're implementing the slavery and trafficking risk orders. We're applying for those. We're providing evidence to say this employer is a risk to the public and the workers if they carry on this way and then they're continuing to exploit and this is unacceptable and it might get worse. We put conditions around people to ensure that their behaviours change. And if they don't, then we'll apply for charge decisions around breaches.

I have the risk orders.

Suzanne (Guest)1:14:26

Ken, can I stop you there for a moment? Two things. First of all, I'm going to give you some questions now. But also, we do have four more presentations after you. We do 1:00 o'clock. So I I just wanted you to be aware of that. Some of the questions have been answered. I know deep with put in about the relationship of GLAA with the responsible cardboard scheme. And Alicia has come back to that so people can see that in the chat. And York has gone about a link to car washes and some of the victims we've discovered.

Jennifer Baines1:14:27

Yes.

Jennifer Baines1:14:34

I know.

Yes.

Suzanne (Guest)1:14:56

Also work in car washes on weekends and I understand that Donna has come back to that, saying we don't have as much intelligence on this as we would like. Thomas Price did ask something else in relation to agriculture, which I'll put to you now, just wonder if your risk profile for agriculture feeds into the senior seasonal seasonal labor review being carried out by the Home Office and Deborah to be published by April 2023, do you have an answer to that?

Jennifer Baines1:14:58

Yeah.

Uh, I.

I do. I do believe it does, but I think what I will do is I will put you in touch with the the four P plan owner around agriculture because they will be doing a lot more work in that area, so they'll have better answers for you, as it were.

Jennifer Baines1:15:44

It's that's helpful.

Suzanne (Guest)1:15:45

Umm. And just to go back to Deep's question about the relationship of GLA with the responsible carboard scheme, they say developed with the support of and he's wondering if support means money or intelligence or something else or all of the above. Do you have an answer to that?

Jennifer Baines1:16:03

I don't believe we give them any money. Uh, certainly not. Umm, we work very closely around what they're doing with with regards to this game. It is a bit of a standalone and I would implore you to go and read the most recent article that I highlighted in the Guardian and where it states the the statistics around the responsible car wash schemes visits.

Jennifer Baines1:16:27

And and and how that fits in with our research and our intensification. So yes, we work very closely together, but.

The aims is slightly different because responsible call team are trying to licence people, whereas we're trying to find the problems and it's it's slightly different relationship but a very positive one. I hope that answers the question.

Suzanne (Guest)1:16:49

Thank you. Yeah, if you just do your last item quite shortly, as you said you were going to do in a brief way. So we can hear from the other presenters as well and give them enough time.

Jennifer Baines1:16:55

Yes.

No problem. You will be delighted to know that I have about 1 1/2 minutes to talk to you about the care sector. So as I say I am very enthusiastic about the hand, car washes and agriculture and so Megan, if you could just move on.

For me, please, actually there is no next slide is there. I'm just talking about the care sector. So care sector, we're gonna go through that really quickly because it's not necessarily that relevant to life, Labour users or providers currently. What we have seen in the care sector recently is a referrals with regards to sponsorship issues, visa threats, work finding fees, false promises, seasonal workers, scheme issues.

Jennifer Baines1:17:43

And Ian Waterfield is leading that nationally across all of the agencies. Again, we're all working together, coordinating, essentially ensuring that the right agencies are responding to the right allegations and ensuring that the exploitation that is detected is dealt with swiftly and appropriately by the right agencies. And that's it from me. So thank you for listening to me. And and I will hang around in the background if that's OK.

Suzanne (Guest)1:18:13

You please hang around the background. We may be calling on you again, but we're going to move on to seeds in a workers scheme. And that's Serena Barton. Three. No. Do you want to make yourself visible?

Excellent. Hello, Serena. The floor is yours.

Serena Barton1:18:30

Hi, Susan. Thank you, Suzanne. So good morning everyone. I'm Serena and I am the senior licensing officer and I work on the regulation team and have oversight for the licensing team and or anything licensing based. I'm also the plan owner for seasonal workers scheme.

Now talk to you a little bit about that today and what that means.

And can I got a next slide please, Megan?

So I'm I'm sure you will know how the seasonal workers scheme works, but I thought I'd be a good idea to go over it this morning. So the design it's designed to provide workers for the edible horticultural sector and that was, that includes poultry.

There is a formal visa route for workers to apply to be part of the scheme, and they and they have to have a sponsor to be able to come into the UK to work as part of this scheme, the seasonal worker scheme operators, sorry, lots of words. There has to be GLAA licensed. That's one of the criteria for anyone to be given the seasonal workers scheme licence.

Workers can be sourced from any part of the world and previously significant numbers came from the Ukraine. However, due to the conflict over in Ukraine that's disrupted the flow of workers and so on, seasonal workers, scheme operators are now looking further afield for workers and to bring workers in, and that is presenting a risk in that we don't have the links in all countries to know what the labor laws are rather than for us to be able to then ensure compliance.

As as fully as we'd like. So that is a little bit of a risk there. And also we workers are having to pay work finding fees in some cases and obviously that's that's not allowed, not acceptable.

So that's also a risk.

Operators who source workers and place them with the growers, have an ongoing responsibility for work or welfare, and so it's not that you can't just bring workers in, place them. And then that's your that's your responsibility. And there is ongoing due diligence that you need to be undertaking.

Now the next slide please my friend.

So it's really important to note that the GLAA is not the lead agency for the seasonal workers scheme. We don't make the decisions on who's granted and operator licence that's that's decided on by UKVI.

But GLAA's role is to ensure that businesses are supplying workers in a compliant manner and that they are compliant with the licensing standards and where that's not happening and where there is non compliance, we will take action as and when necessary.

We can support UKVI with the farm visits to check on worker welfare and make sure workers are receiving. You know all the benefits they should be on all the entitlements and they're being treated fairly as part of the seasonal workers scheme.

Next slide, please and then?

The what are we currently doing? We are receiving a a really large number of applications from businesses based overseas and because.

They are coming from overseas and we don't have the links with those.

And government agencies to make the the checks that we would normally do, the process is taking a little bit longer. However, we are working with colleagues in the Foreign Commonwealth and Development Office to link into those embassies to ensure that we've got a good picture and good understanding of what the label laws are in the source country. So we can make sure we've got as much information as we need up front to be able to assess compliance.

They're also investigating allegations of worker exploitation that we're receiving from from the industry and we are continue to work with in partnership with colleagues across government, including Defra, UKVI and the Home Office.

Thanks, Megan.

But as Donna said earlier, one of our control strategy priorities is.

The seasonal workers scheme and that is because we recognize that the scheme has led to a number of allegations of worker exploitation. So it's important we're aware of that and we have a good intelligence picture so we can.

And prioritise our resources to tackle the exploitation that's arising from that activity.

And to make sure that we're doing all we can, we are developing a plan to address the different aspects of the exploitation that we're seeing.

We'll just go on to talk a little bit about the four P's and what we're doing. So the four P's are prevention and protect, pursue and prepare.

So I'm going to talking about prevention. What we're looking at doing is gauging with the seasonal workers operators to understand what their recruitment portfolio is. We want to really understand and have a really good picture of where the workers are coming in, from what countries and so that we can then link in with those embassies and make sure we know what the labour laws are. So we have a really good picture there. So we can do a little bit more work around that.

We promoting the just good work up so workers have a an understanding of what their benefits are, what they're entitlements are when they come to work over here in the UK.

And they're also in the process of producing video to help manage worker exploited and manage worker expectations. And so they know what to expect when it's when they come over, you know, what kind of accommodation should they expect? What's the weather like? What's the work they will be doing? That's really important to manage those expectations. And they know what to expect.

Serena Barton1:28:12

The workers are.

The workers are employed by the end users of the labour user, so although the the sponsor, it brings the workers in, they bring them into their supply them on to the end user. So they actually employed by the end user so that they that that doesn't affect.

Their employment as such, because they're not employed by the seasonal workers licence holder.

The workers are still protected in that way.

Suzanne (Guest)1:28:41

Thank you. Kelly Shields has just given an update here that two round tables took place in late 2022 to discuss key issues and all supply chain stakeholders were involved. Task and finish groups have been set up to develop training materials and guidelines for labor users and scheme operators. Source country risk are also being addressed.

I believe that there are other chats, UM, but they've been answered by Leisha. So I think if something else comes in ohh I've got another point from Joanne Young who says I understood the SWS visa would be cancelled if the sponsor loses their license. I don't know if you can comment on that.

Serena Barton1:29:24

So the the SWS licence to if you're if an ad business applies to have an SWS license, one of the criteria is that they have a GLAA licence. If the GLAA licence is revoked for whatever reason, that would affect.

The validity of the SWS license, but like I said earlier, we're not responsible for deciding who has a licence or how that scheme works. That's the UKVI scheme, or supported by the GLAA licence.

Suzanne (Guest)1:29:53

Thank you. On that note, I think will bring your part of this to an end, though other people may ask questions and I may bring you in later, but we're gonna go on to umbrella companies and Martin Jones is doing that. So Martin, if you could join us. Thank you very much, Serena.

Serena Barton1:30:06

Thank you.

Suzanne (Guest)1:30:09

I I'm here of a hand raised by Andrew. But Andrew, if you have question if you could put it in the chat please.

AA: 1:30:16

Yeah. So it was just in response to the what happens to the visas, but we can cover that in the UKVI bit.

Suzanne (Guest)1:30:21

Thank you, Andrew. Yes, you're coming up later on the seasonal workers scheme. So we'll hear from you then, but we're going to take Martin Jones now talking about umbrella companies. Andrew, you can lose your hand.

Martin Jones1:30:35

OK, good morning all. I think it's still morning. Another two minutes to 12:00 o'clock. So I am right on that. Just for a change.

Yes, Martin Jones, I am one of the senior compliance officers who have oversight of the compliance team with a colleague and we're part of the regulation team of which.

Serena has already mentioned, and we work very closely together with licensing.

So if uh, we move on to the next slide, please. There we go, right. One of the control strategy priorities is umbrella companies and I own this area of the control strategy priority.

So why is this a priority? Well, in real terms it's not real visible.

Area for for us or for anybody really that that engages with these because it is in plain sight, but only through due diligence can we identify where these companies are actually operating. And we've seen an upsurge of these come into this sector with businesses already operating outside of the GLA sector already operating with these umbrella companies and.

Which will also talk about in a minute or two, Umm, about micro umbrella companies who are coming into our sector and through the application inspection process we're identifying these, but I'll go through a little bit about umbrella companies. Probably most of you are fully aware of what an umbrella company is and we all know that potentially they're often used by recruitment agencies to pay temporary workers.

And in most cases, the umbrella company will employ the worker and they will pay their wages through pay a YE, but it does not find the temporary worker the work that's done by the recruitment agency and the umbrella companies appear quite attractive because they can offer free services to the agency that utilizes their services or reduce the cost of payroll systems by going through their payroll.

Martin Jones1:32:41

So with. With that in mind.

Martin Jones1:32:45

Where we have these umbrella companies, they'll show. Uh, a couple of slides out of the model for an umbrella company. And what I'm going to talk on about as well is these micro umbrella companies as well that where we have an umbrella company pushing workers into micro umbrella companies, this can lead to fraud, which I like go a little bit more on in a minute. But the mini umbrella for all creates an uneven playing field for all those businesses that are out there and.

These the ones who follow the rules, but the micro umbrella companies don't, and this leads to all sorts of things. So the fraud is fine, primarily sorry based around the abuser 2 government incentives, which is aimed at small businesses and that's flat rate scheme, VAT flat rate scheme and employment allowance.

The type of food can also result in non payment of other taxes, such as PAYE, National Insurance and VAT. This is reducing vital funding for the public services that we all rely on.

So the creation of them in the umbrella companies are create complex layers of businesses within the supply chain and help facilitate the fraud. And that again creates that even playing field.

But also in an importantly can lead or can be run by organised crime, which is a huge threat to the UK Exchequer.

A lot of this will be come within the sort of HMRC remit, but we're out out and about and we come across these companies so we do report matters too. HMRC that we that we find. But what this can do is create offences under section 12 and Section 13, section 12 unlicensed supply and Section 13 of accepting supply of workers from an unlicensed source because umbrella companies require to be licensed by the GLA.

And all those Umbrella Micro umbrella companies that are set up by these umbrella companies to supply workers through the main agency into a labour user required to be licensed as well, because they're all separate legal entities. And that's the important thing to to remember that these umbrella companies and micro umbrella companies are all separate legal entities.

Martin Jones1:35:07

And cannot be covered by the one licence by the Employment Agency, whether the worker originally gets his work from. So if you move on to the next slide, please make it. Thank you very much. So a simple umbrella model is here where we have an end user.

Suzanne (Guest)1:49:22

OK.

Well.

That's another thing that those on this webinar might be able to think about it. They're getting these emails. I'm sure Andrew will be happy to share it with you. I'm going to move on now, Martin, thank you very much for that. We've got your Martin Plimmer is gonna talk about shellfish gathering.

Martin Jones1:50:01

Lovely. Thank you.

Suzanne (Guest)1:50:07

So if you could come online.

Martin Plimmer1:50:09

Yes, good afternoon, everybody and hopefully we'll save the best till last, yeah, on Martin Plymouth on one of the four senior investigating officers that work for the GLAA. We all have a geographic responsibility. I cover the northwest and I mentioned that because there are challenges that face me that face the across the GLA as well in that I cover the top end of whales North Wales, I cover the North West of England. I also cover Scotland and Northern Ireland.

And the GLAA legislation differs across countries and it is, uh, particularly relevant as well how there are differences across the UK, in how shell fishing is approached and and done. So if I go to the next slide please.

So if you could throw up without being overdramatic, the whole reason the GLAA exists is because of that slide. There, it's nearly 20 years now since the Morecambe Bay tragedy and it is really.

The foundation of what I and everybody else in the jail, it gets fired up about and why we do what we do and I always worry that we go the more convey tragedy and we just throw it out in a sentence. We really have to look at where we came from. The reason we exist and it is to protect exploited workers and we can't have a more stark example of that that in 2004 those sad individuals lost their lives collecting shellfish on the shore in Britain at Morecambe Bay. So the whole reason we were set up was to hopefully stop that happening again.

Martin Plimmer1:51:44

We haven't had any major tragedies since that day, and I know, and I can say with hand on heart, that the licensing scheme has helped prevent that. We have some near misses and it's still a high risk area for us. So we can go to the next slide please.

Not that I'm coming from skilled work and know that that does happen on skilled work.

Martin Plimmer1:58:02

The exploitation that we have seen historically, he's probably around national minimum wage.

That are modern slavery issues and violence amongst rivals, and what we've seen in recent years, the main form of exploitation is that where you have a permitted scheme and people hold that permit to collect in a certain area, like the dsquery criminals will approach them and take over their permit, they will force them to say they're sick and they can then delegate their permit to a nominated person. Again, there are steps in line to.

To prevent that, the other form of exploitation we've experienced recently is that they will threaten and approach people and say you will gather on my behalf or they pay the fees for somebody to obtain a permit at the outset, but ostensibly they are working for the criminal. But again, the legislation is very difficult. It's very tight for us to identify that they are unlicensed. Gangmasters are doing that mostly offences.

Or around poaching around taking from contaminated beds from unclassified beds, false records, and that doesn't come under the GLA legislation. So the constant challenge for us and part of this process that I'm involved now is to look at again how we interpret and enforce our legislation. Do we need to look at the business models that are taking place at the moment? Are they being used to circumvent our licensing system?

And we're always aware of that and we're always reviewing that. But part of the process, so I'm going through is that do we need to look at the briefs that we send out, which we do regular, but it's just part of that process. So we look at the have to look at who needs a licence, I have to say that we have a low number of licence holders now in the shell fishing industry or low it is a.

A risk sectors for us, but we have to look at why that is. Why if people relinquish their licence, are they? What is the reason for that? Are they operating with that license? So that will be part of the four P process that we go in. I've got education of the industry. I think that needs to be re education of the industry. We need to revisit everything we're doing and the industry includes the gatherers. We need to inform them.

Martin Plimmer2:00:25

Uh to spot the signs of self exploitation. How are there been approached? How are they being targeted and to give them that assurance that we will protect them at that cetera, we need to work more closely with partners and we need to be more involved in a joined up approach. It may well be that I say uh legislation isn't relevant in a number of situations. However, we use the legislation of partner agencies to ensure our end goals.

We do have intelligence gaps.

The challenge with intelligence for us is that we get a lot of intelligence that we'll say 3040 people gathering shellfish on the side, for example, at Morton Sands in Liverpool.

From that intelligence, those 4050 people could be.

Gathering legitimately as an individual person, you can gather up to 5 kilograms for your own personal use. What we have to target is the commercial gathering by hand, where it's organized by another individual, so we get a lot of intelligence to challenge for us is to sift through that and try and get touch. So we need to educate our partners when they are reporting intelligence. We need to educate them to say, be more specific. What makes you think? Was there somebody there?

It was obviously organising them, handing out equipment was the payment taking plus, so those intelligence gaps that we have to do difference in regional approaches, I think we have to be of certainly.

Absolutely. I've nearly finished.

Yep.

Suzanne (Guest)2:02:03

Be then immigration. So you have 5 minutes left.

Martin Plimmer2:02:04

Absolutely. I'll. I'll be finished well within then we have to, we need to be a strong voice in different regional approaches and try and encourage the the legislators to to make it across the UK and Scotland and Northern line. So it's a joined up approach.

As I say, we have to differentiate and educate between personal gathering against commercial gathering and we will also have to be careful and educated against cultural profiling. And by that I mean that we experienced during COVID because of people being laid off from work. We had an extremely large increase in members of the Asian population turning up and gathering shellfish, and that resulted in lots of intelligence reports coming saying this was happening that was happening. The vast majority of those were legally gathered.

Shellfish so as an organisation we have to protect ourselves around that we don't jump to assumptions around ethnic profiling and things like that so.

Again, I appreciate him on on the warning thing, but if I could just make a plea to everybody who's on the the the webinar. If there is anybody within the industry that has an insight into this that wishes to discuss it further with me, then please contact me. But yet on I'm open to questions but that's it.

Suzanne (Guest)2:03:23

Thank you, Martin. You're very good at keeping to time. We don't have any questions for you quite yet. There might be more to come in when we move forward. So don't go away. And of course you've given your plea for people to give you information if they have it. And I'm sure that was heard very clearly, but I'm going to thank you for now and I'm going to move on to the last agenda item, which is the seasonal workers scheme in 2023. We've got Jane Somerville from UK Visa and immigration and.

Martin Plimmer2:03:43

2:05:56

Migrant workers to come in. So that's the sponsorship side. The sponsorship compliance side is.

Primarily as historically been based on Intel, which is largely generated from within UKVI.

And also I'm kind of the internal UKVI systems that we use for monitoring sponsors. We also react react to external Intel from a lot of the agencies that are on this call. We've done a lot of work with GLAA on care homes. We just run a bit care home job and generally reacting to where areas of concern are being notified to us. We will look at those sponsors, we've got capability to visit those sponsors, but I've only got 70.

2:06:44

Visiting officers and with 65,000 on the register then we're obviously looking at working a little bit smarter going forward in using electronic and data and digital methods to kind of make sure we've got compliance sponsors on the register. We'll generally look at pay slips, make sure that how the sponsor is operating and how they're employing those migrant workers matches up to what they told us they would be doing when they first got their license.

We do have power to suspend sponsor licenses and then we'll conduct a slightly more in depth investigation. We can interview the migrant workers, we can interview the sponsors and if we're not satisfied that the meeting, the sponsorship duties, we will suspend that licence, then it representations and then we've got the capability to revoke their sponsor license, which we do frequently do. It's not a kind of toothless thing. We will investigate and we will take sponsors off the register.

Where it's slightly different is that I'm not operating under legislation, I'm operating under sponsorship guidance, so I can only react to what is in breach of that sponsorship guidance. Anything that I see outside of that, more than slavery type referrals, then I can only refer them on to the relevant organizations.

So I just lost my train of thought there for a moment. So yeah, I'm operating under guidance legislation where we're we're she's had potentially differ from a lot of people on this call.

The agricultural sector has primarily been part of that larger sponsorship picture, but following an inspection and a review late last year, we're now gonna have a separate seasonal agricultural compliance element because the niche of the kind of agricultural sector in that there's.

10s of thousands of workers, 35,000 at least spread over a number of farms spread over a number of geographical locations right up and down the country. But where it differs from other sectors is that there are only at the moment for sponsors. So those four sponsors basically have the 10,000 workers split between them and there then supply them to a network of farms. So it is a little bit different in the sponsor, usually has to manage.

Control the workers on a daily basis, but slightly different in the source environment. And what Jane's gonna go on to now is that how that solves environment is going to change over the next year and we'll see it a kind of much tighter and a much more engaged sponsor compliance team. And I think for for, for this year coming forward, we need much more engagement with the four sponsored providers.

We need much more engagement with a lot of the agencies that are on this call now to kind of make sure that we're seeing at the intelligence that we need to and also the where we've got people out visiting these farms that they're aware and alive to some of the issues that have been raised already in this presentation. So if you are happy with that journal handed over to you.

2:09:56

Just come off meat like we get uh, yes, as an Andy alluded to, there seasonal workers team is a small team based in Sheffield that currently you sort of look at sponsors, uh, saw sponsors through a blend of data analysis, compliance inspections at forms, interviewing migrant workers and the sponsor locations. I mean they have been visited in the past but this is not just putting in place. The small team just to visit farms and hopefully we'll have them up and running.

By the summer and and that's that's in response to the independent chief inspectors report that was published in December, that we've accepted all the recommendations and was there Justin, that we put the dedicated team and in.

So we are currently putting together sort of training material and putting them people in place. So it's early days, a couple of other recommendations by that report, that communications sorta, which is that the engagement road map, communications engagement, Rd, road map and the document for the roles and responsibilities is in hand. But that's another areas of the business.

So Megan kind of the next slide.

So what we're actually hoping to do with these UM, visiting offers going around just the farms as to better, maybe closely more closely monitor the workers welfare, UM and spent more time interviewing them and hopefully interviewing more than we're able to up until now.

Umm.

And so and what we things that we're gonna be looking at during a visit to a farm which could we we understand I mean for our visit to a farm could take days and some some have only a few workers play some will have 10s of hundreds and So what would be looking at is the environment and make sure it's safe and complies with health and safety.

We're we're checking to make sure that the farm takes steps to make sure that the workers understand, so provide information in their own language as well as English. They're treated fairly by employers. I'm not penalized for failing to work at the fair piece rate.

And the the sure that they're given their contract in their own language as well as English and make sure that they properly the minimum wage minute is £10.10.

And make sure I'm getting that there's been no zero hour contracts.

And obviously regular breaks, holidays and and to make sure that they know what processes and procedures are in place if they are sick or injured at work.

That's the next leg, Megan.

Suzanne (Guest)2:21:17

Please continue. I I've got another question here. I didn't know if you'd finished.

2:21:20

No, I'll call that finished and and let's have the other question.

Suzanne (Guest)2:21:23

OK, I've got one from Joanne Young, who says are you able to answer the question on whether workers visa if a workers visa is cancelled if they're sponsor loses their license?

2:21:35

If a sponsor loses a licence with the number of options, generally speaking, and this is for skilled worker or any any.

And agricultural workers as well, is that that worker that migrant worker can go and work through another sponsor provided.

2:21:53

They can go work through the company provided that company is also on the sponsor register and they're doing the same kind of work. So in theory and in fact, in practice, if somebody on the agricultural scheme, the sponsor loses their license, they can go and work for one of the other providers.

Suzanne (Guest)2:22:11

And I've got one from Andy York, which I'm not sure with answered, because I think it was with understood at one point and he asked is there also a plan to look at compliance with the skill work of Visa route in addition to the seasonal workers route?

2:22:25

Yeah, that's all under my command now and certainly from my perspective, skilled worker compliance as probably every single agency on this call, we suffered through not being able to do visits, physical visits, so skilled worker compliance will also be ramped up over this year. We've just done, as I said earlier, we've just done a an operation looking at care homes and we're bringing in various kind of digital.

2:22:56

Methods and recruiting visiting officers so we can kind of we need to get out and start assuring compliance across that register of 63,000 organizations.

Suzanne (Guest)2:23:07

Thank you. I think I have now covered and you've covered in your responses all the questions that have come in so far. I don't know if you and Jane want to conclude with any final remarks. That's when a lot of people offering support and wishing you to get in touch with them. I've got one more. Sorry, I spoke too soon. And can you direct us to the guidance scheme rules for the Tier 5 where details if an operator loses its status, the sponsor worker can move to another operator.

2:23:39

Yeah, I think, well, yeah, it it.

Awful answer, but if you go on the on obviouslygov.uk and look at the sponsoring of sales worker.

It should be in there about what? What happens to a.

A migrant workers certificate of sponsorship. If the sponsor is.

Loses the licence.

There's a 60 day, I mean inferior. A worker can also be given 60 days to leave the UK.

2:24:07

But more often than not, these workers are on such a short period of time in the UK anywhere that what's left of their leave will just be allowed to run down.

2:24:16

So I'll be 60 days from the revocation of the sponsors licence. The migrants got to leave the UK or they can find employment with another sponsor in in that same area of work. Anybody who wants to get in touch with me.

2:24:31

I've seen the sunrise from labour providers and and and sing from the NFU as well.

2:24:35

And it's andrew.edgar@homeoffice.gov.uk usual one drop. Drop me an e-mail.

Going forward this year with souls, we need to engage more with the providers and the people around the providers as well, and that's something I do intend to do.

Suzanne (Guest)2:24:42

If.

Andrew, if you could put that in the chat on Rachel's come back and said the guidance says they cannot transfer between operators.

With a question, so I don't know if that's a statement or question.

2:24:59

Ah.

Not that I'm coming from skilled work and know that that does happen on skilled work.

Suzanne (Guest)2:25:09

Right.

2:25:09

Yeah. I'm gonna just interrupt there and say that Umm Tier 5, as far as I'm aware or Tier 5. Sorry, temporary workers, what used to be Tier 5.

And can't.

Transfer as I understand it, so once an operator loses their licence then they would have to leave.

Suzanne (Guest)2:25:27

Understood.

2:25:27

That employment.

Suzanne (Guest)2:25:28

So if both of you could put your contact details in the chat, that would be helpful. If there are a lot of people who want to help you. So I think it would be useful for you.

Right. I don't have anymore questions. Jane Andrews gone off the screen, so I can't say goodbye to him in that way, but we just think very is again. Excellent. Nice to see you again, Andrew. Can I? On behalf of the webinar participants, thank you both for an excellent presentation. I know a number of people put that in the chat already, but I wanted to thank you. It was really good to have you following on from what the GLAA is doing in this area.

2:25:47

OK.

Suzanne (Guest)2:26:08

In relation to aspects of our control strategy, so we probably you were so good, we probably invite you again so.

2:26:15

Oh, thank you.

2:26:16

Not that's not work then, is it?

Suzanne (Guest)2:26:19

Ohh and also and I've been reminded by Katherine, but I was going to do it anyway. Katherine is to remind those on the webinar who have been with us throughout this really interesting session. If they could please complete the survey, it helps us in making webinars and other events better. So it's on the link there. We really want it. Thank you David for saying it was an excellent presentation. I think that goes to you Andrew and Jane, we have now come to almost 12:00 o'clock.

Suzanne (Guest)2:26:49

So I think it is time actually to end the webinars. I said there is going to be recording, we will answer any questions that haven't been answered. But I think we've done most of them and we will be having another one of these webinars in a few months time. So thank you everyone who was participating, listening, asking questions and who presented.

Suzanne (Guest)2:27:14

We'll close the webinar now. Thank you.

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