Coleg Gwent Internal Audit Report 2014/15 Staff Performance Management. Assurance Rating:

Transcription

1 Coleg Gwent Internal Audit Report 2014/15 Staff Performance Management Assurance Rating:

2 Distribution List: Final Report Audit Committee Principal Vice Principal, (Resources and Financial Planning)/Director of Finance Governance Officer Responsible Officer(s) Date of fieldwork: June/July 2015 Date of draft report: October 2015 Date of final report: October 2015 This report and the work connected therewith are subject to the Terms and Conditions of the contract dated 22 September 2014 between Coleg Gwent and Deloitte LLP. The report is produced solely for the use of Coleg Gwent for the purpose of providing internal audit services. Its contents should not be quoted or referred to in whole or in part without our prior written consent except as required by law. Deloitte LLP will accept no duty or responsibility to any third party, as the report has not been prepared, and is not intended for any other purpose. This report has been prepared on the basis of the limitations set out at Appendix F Deloitte LLP

3 Contents Page 1. EXECUTIVE SUMMARY Background Audit Objectives and Scope Key Findings Conclusion Restriction of Use Acknowledgement OBSERVATIONS AND RECOMMENDATIONS Annual Performance Reviews Medium Priority Performance Management Policies, Procedures and Guidance Medium Priority8 2.3 Assessment of Probation Period Medium Priority Completion of Teaching Observation Forms Medium Priority Linking Individual Objectives to Department/College Objectives Low Priority APPENDIX A REPORTING DEFINITIONS APPENDIX B STAFF INTERVIEWED APPENDIX C TERMS OF REFERENCE APPENDIX D MEANING OF THE SMART ACRONYM APPENDIX E EXAMPLE OBJECTIVE SETTING FORM APPENDIX F STATEMENT OF RESPONSIBILITY Deloitte LLP

4 1. Executive Summary 1.1 Background The internal audit assessed the adequacy and effectiveness of Coleg Gwent s (the College s) internal controls in operation regarding Staff Performance Management. The internal audit work was carried out through discussion with relevant staff (a list of staff interviewed can be found at Appendix B), examination of documentation and sample testing, as necessary, to confirm the effectiveness of the controls in place. 1.2 Audit Objectives and Scope The internal audit assessed the adequacy and effectiveness of internal controls in operation. Weaknesses were brought to the attention of management and advice issued on how particular problems may be resolved and controlled. The internal audit sought to provide reasonable assurance over the following areas: Staff performance management policies and procedures have been established and communicated to all relevant members of staff; Roles and responsibilities for staff performance management have been established; There is a performance management framework in place for staff including standard objective setting and appraisal forms; There is a formal feedback process in place; Staff objective setting, appraisal meetings and sign off of appraisal forms have been completed on a timely basis; Management are able to identify whether all appraisals and the associated paperwork have been completed; Individual s objectives are clearly linked to the College s strategic objectives; Sign off of a probation period is carried out on a timely basis and after the performance of the individual has been formally considered and agreed by management; and A process is in place for addressing underperformance issues and this process is followed where necessary. Meetings The internal audit also included meetings with four members of staff to identify their opinions on the effectiveness of the staff performance management system Deloitte LLP 1

5 1.3 Key Findings All members of staff at the College should receive an annual performance review with their line manager. During this review, a standard Performance Review Form should be completed which is made up of various sections, as illustrated below: Sections of the Performance Review Form Section A: Your Details To record details such as name, job title, name of line manager Section B: Looking Back To record comments on performance and grade, from both the member of staff and their line manager, against each target. Section C: Barriers To record comments from both the member of staff and their line manager if there have been any barriers to meeting the targets. Section D: Where am I now? To record the member of staff and their line managers rating of performance level against core criteria for all staff and any other relevant criteria, along with a summary of the discussion. Section E: Learning and Development Outcomes To record any learning and development activities undertaken, how the member of staff has used what they have learnt and in what ways that has improved their performance. Section F: Looking Forwards To record targets for the following year, agreed target dates and how they will be achieved and measured. Section G: Learning and Development Needs To record if any learning or development needs have been identified during the review process. Section H: Additional Information To record if there is anything the line manager can do differently to improve the member of staff s performance and any additional comments from both the member of staff and line manager. Section I: Approval Form to be signed off by both the member of staff and line manager. The Performance Review Form documents the steps relating to the annual review as follows: Line manager sends employee the Performance Review Form and letter with invitation to the meeting at least two weeks prior to meeting. Employee completes sections A-E and returns the form to line manager no later than one week prior to meeting. Line manager completes section B in draft prior to meeting. Review meeting takes place and sections F-G are completed. The line manager also completes section D. Line manager finalises section B & C based on discussions with the employee. This can be completed during or after the meeting. Both parties complete section H & I. The form is completed and signed off by both parties within four weeks of meeting. Learning and Development Needs form is sent to the Learning and Development Department. A copy of this form should be kept by the employee and the line manager Deloitte LLP 2

6 In addition to undergoing the standard performance review process, teaching staff also undergo an observation at least once a year, during which an observation form is completed. During observations the observer will document the observees key strengths and areas for development along with comments from learners. All new members of staff are required to complete a probation period of six months when starting with the College. Line managers are required to complete probation reports for members of staff once they complete the first six months. This form will record whether or not the member of staff has successfully completed the probation period. There is a Capability Policy and Procedure in place at the College which documents the process to be followed when addressing underperformance. There have been no formal instances of a member of staff underperforming since 1 August As part of this internal audit we met with four members of staff in order to gain their opinions on the effectiveness of the staff performance management system. We note that no specific issues raised during the discussions were noted by all of the members of staff, therefore we have not raised any recommendations as a result of the discussions with staff. However, we have included all of the points raised below for management s consideration: Two members of staff noted difficulties in using the online system for performance management. These issues included: o It is not clear what information had been put into the system by the line manager and what the appraisee needs to complete; o They found the process to be a lot easier when using paper forms; and o The online system does not work properly and has previously lost data. In addition one member of staff noted that it is not clear what the expectations of the College are in relation to the online system. One member of staff noted that their line manager still uses manual forms and they feel that it would be beneficial for them to switch to using the online system; One line manager noted that the process for identifying training available to staff should be improved as it is currently a line manager s responsibility to identify any training that staff should attend so it would be useful if the HR Department could send out a prompt of suggested training courses so that staff understand the options available to them; One member of staff noted that she only received feedback during the annual review meetings and would prefer if feedback was provided on a more regular basis. The member of staff also noted that her annual performance review is usually very focused on setting objectives rather than reviewing the year and discussing her views on how things have been going and that she would prefer the appraisal to be split more evenly between setting objectives and reviewing the previous year; and One line manager noted that training in relation to performance management would be beneficial as currently no training has been provided in this area. The line manager noted that in lieu of training from the College, she replicates good practice and experiences from other organisations she has previously worked at. We have identified four medium priority issues which we consider require management s attention and provide scope for improvements to be made. These concerned: Annual Performance Reviews - We identified the following issues on inspecting a sample of 20 Performance Review Forms: o Performance Review Forms had only been completed for 12 of the 20 members of staff (however, in two instances where this was not completed this was due to the members of staff being new joiners so this is satisfactory). o Of the 12 completed performance reviews: In three instances performance reviews had not been completed within the last year. We were unable to identify when a further three performance reviews had taken place as the Performance Review Form had not been dated; 2015 Deloitte LLP 3

7 In one instance, the Line Manager did not provide feedback against all of the member of staffs objectives for the year; In three instances performance objectives had not been recorded for the next period; In one instance, the staff member s performance could not be rated against their objectives as they had set none for the year despite being employed the College for eight months; and In two instances the Performance Review Forms had not been signed off by the Line Manager or the member of staff and in one further instance the Performance Review Form was not signed off by the member of staff. We identified that there is currently no central monitoring of the completion of performance reviews. The HR Team is able to see the Performance Review Forms that have been completed through Passport (the electronic performance management system), however, forms that are completed manually are retained by line managers. It is recommended that each member of staff at the College receives a performance review with their line manager on an annual basis. All fields of the Performance Review Form should be completed as part of this process. In addition, the College should centrally monitor the completion of annual performance reviews and implement a procedure to chase those line managers that are not completing the reviews on an annual basis. Performance Management Policies, Procedures and Guidance - We identified that there is a Performance Review Policy in place for non-teaching staff but this has not been reviewed since October 2009 despite the date of next review on the policy s cover stating Autumn There is no equivalent policy in place for teaching staff. The guidance documents included within the Performance Review section of the intranet all include an implementation date of November 2009 and an out of date review date of November We identified that the Performance Review Form states that objectives for the next review period should be SMART (Specific; Measurable; Achievable; Realistic and Timely). However, the Target Setting and Personal Development Objectives guidance explains the S, M and A of the SMART acronym but states that the A stands for agreed, which is inconsistent. The College may consider using the meaning of the SMART acronym at Appendix D. It is recommended that a Performance Review Policy for teaching staff is established and that all staff performance management policies, procedures and guidance are kept up to date and reviewed on a regular basis. It should also be ensured that guidance is consistent with Performance Review Form. Assessment of Probation Period - We identified the College has a probation period for all new members of staff which lasts for six months. On completion a probation report should be completed by the staff member s line manager. On inspecting a sample of 10 probation reports, we identified the following issues: o Four of the 10 probation reports were not completed in a timely manner (within one month of the probation period ending) with the latest being completed 199 days after the probation period ended; o One of the 10 probation reports was not signed off by the member of staff; and o The date of discussion was not recorded on one of the 10 reports. We also identified that the probation reports provide space for sign off by the Campus Director, however, it is not clear when this sign off is required. We identified on discussion with the Director of Human Resources that it is only necessary for a Director to sign off the report if there have been any exceptional circumstances such as underperformance or an extension to the probation period. It is recommended that the College implements a set timeframe for line managers to complete probation reports and reminds members of staff to record the date that the discussion took place and ensures that the reports have been appropriately signed off. The College should also make it clear when a probation report is required to be signed off by the relevant Campus Director. Completion of Teaching Observation Forms - We identified on discussion with the Director of Human Resources that each member of teaching staff should undergo at least one observation every year. The 2015 Deloitte LLP 4

8 observation forms completed should also be signed off by the observer and observee. However, from a sample of 20 members of teaching staff selected, we identified the following issues: o One observation form was not provided during the time of the audit as it could not be found; o Only one of the 19 observation forms inspected was signed off by both the observer and observee; and o Three of the 19 observation forms had not been completed within the last year. We also identified that the Performance Management Review Form does not include a section to assess performance based on findings from observations. It is recommended that all teaching observation forms are signed off by both the observer and observee and that at least one observation is completed for teaching staff on an annual basis. The College should update the Performance Management Review Form for teaching staff so that it includes a section to assess performance based on findings from observations. In addition we have raised one low priority recommendation concerning a minor issue which nevertheless needs to be addressed. Detailed findings are set out in the Observations and Recommendations section. 1.4 Conclusion Based on the work undertaken as detailed in the Audit Objective and Scope section, our overall assessment is that the classification of assurance that can be taken in respect of Staff Performance Management is substantial assurance. Management should be aware that our internal audit work was performed according to Public Sector Internal Audit Standards (PSIAS) which are different from internal audits performed in accordance with International Standards on Auditing (UK and Ireland) issued by the Auditing Practices Board. Similarly, the assurance classifications provided in our internal audit report are not comparable with the International Standard on Assurance Engagements (ISAE 3000) issued by the International Audit and Assurance Standards Board. Our internal audit testing was performed on a judgemental sample basis and focussed on the key controls mitigating risks. Internal audit testing is designed to assess the adequacy and effectiveness of key controls in operation at the time of an audit. Definitions of the assurance classifications and recommendation classifications used in this internal audit report are provided in Appendix A. 1.5 Restriction of Use We wish to draw to your attention that this report may only be used in accordance with our contract and may not be made available to third parties, except as may be required by law. 1.6 Acknowledgement We would like to thank the staff who participated in this internal audit for their assistance and co-operation Deloitte LLP 5

9 2. Observations and Recommendations 2.1 Annual Performance Reviews Medium Priority Recommendation Rationale Priority It is recommended that each member of staff at the College receives a performance review with their line manager on an annual basis. All fields of the Performance Review Form should be completed as part of this process. In addition, the College should centrally monitor the completion of annual performance reviews and implement a procedure to chase those line managers that are not completing the reviews on an annual basis. We identified the following issues on inspecting a sample of 20 Performance Review Forms: Performance Review Forms had only been completed for 12 of the 20 members of staff (however, in two instances where this was not completed this was due to the members of staff being new joiners so this is satisfactory). Of the 12 completed performance reviews: o In three instances performance reviews had not been completed within the last year. We were unable to identify when a further three performance reviews had taken place as the Performance Review Form had not been dated; o In one instance, the Line Manager did not provide feedback against all of the member of staffs objectives for the year; o In three instances performance objectives had not been recorded for the next period; o In one instance, the performance of the staff member could not be rated against their objectives as they had set none for the year despite being employed the College for eight months; and o In two instances the Performance Review Forms had not been signed off by the Line Manager or the member of staff and in one further instance the Performance Review Form was not signed off by the member of staff. We identified that there is currently no central monitoring of the completion of performance reviews. The HR Team is able to see the Performance Review Forms that have been completed through Passport (the electronic performance management system), however, forms that are completed manually are retained by line managers. There is a risk that staff performance is not being monitored on a regular basis leading to any instances of underperformance not being identified or addressed Deloitte LLP 6

10 Management Response The College recognises the current processes are cumbersome and difficult due to technology restrictions which makes accessing the system extremely slow. The policy and process will be reviewed and updated within the next 6 months to make the process easier to use and more effective for managers and colleagues. Responsibility/ Deadline Head of HR May Deloitte LLP 7

11 2.2 Performance Management Policies, Procedures and Guidance Medium Priority Recommendation Rationale Priority It is recommended that a Performance Review Policy for teaching staff is established and that all staff performance management policies, procedures and guidance are kept up to date and reviewed on a regular basis. It should also be ensured that guidance is consistent with the Performance Review Form. We identified that there is a Performance Review Policy in place for non-teaching staff but this has not been reviewed since October 2009 despite the date of next review on the policy s cover stating Autumn There is no equivalent policy in place for teaching staff. The guidance documents included within the Performance Review section of the intranet all include an implementation date of November 2009 and an out of date review date of November We identified that the Performance Review Form states that objectives for the next review period should be SMART (Specific; Measurable; Achievable; Realistic and Timely). However, the Target Setting and Personal Development Objectives guidance explains the S, M and A of the SMART acronym but states that the A stands for agreed, which is inconsistent. The College may consider using the meaning of the SMART acronym at Appendix D. There is a risk that policies and procedures may not accurately reflect current practice if they are not reviewed on a regular basis. There is also a risk that guidance produced for staff may not be wholly beneficial if it is not consistent with other resources. Management Response The College recognises the current processes are cumbersome and difficult due to technology restrictions which makes accessing the system extremely slow. The policy and process will be reviewed and updated within the next 6 months to make the process easier to use and more effective for managers and colleagues. Responsibility/ Deadline Head of HR May Deloitte LLP 8

12 2.3 Assessment of Probation Period Medium Priority Recommendation Rationale Priority It is recommended that the College implements a set timeframe for line managers to complete probation reports and reminds members of staff to record the date that the discussion took place and ensures that the reports have been appropriately signed off. The College should also make it clear when a probation report is required to be signed off by the relevant Campus Director. We identified the College has a probation period for all new members of staff which lasts for six months. On completion, a probation report should be completed by the line manager of the member of staff. On inspecting a sample of 10 probation reports, we identified the following issues: Four of the 10 probation reports were not completed in a timely manner (within one month of the probation period ending) with the latest being completed 199 days after the probation period ended; One of the 10 probation reports was not signed off by the member of staff; and The date of discussion was not recorded on one of the 10 reports. We also identified that the probation reports provide space for sign off by the Campus Director, however, it is not clear when this sign off is required. We identified on discussion with the Director of Human Resources that it is only necessary for a Director to sign off the report if there have been any exceptional circumstances such as underperformance or an extension to the probation period. There is a risk that any underperformance issues may not be identified or addressed in a timely manner. Management Response The commitment of managers to completing probation reports has slipped during the Management of Change period. Going forward, the HR Business Partners (HRBPs) are tasked with following up outstanding probation reports following the production of an HR monthly report on those who have failed to submit completed reports. The HRBPs also have an objective to work closely with line managers following recruitment/appointment of staff to ensure both induction and probation is followed up. This is seen as essential to ensure that under performance is identified early and appropriate steps taken to address the shortfall or to ensure we do not retain the services of those who do not meet the required standards. Responsibility/ Deadline Head of HR Immediate 2015 Deloitte LLP 9

13 2.4 Completion of Teaching Observation Forms Medium Priority Recommendation Rationale Priority It is recommended that all Teaching Observation Forms are signed off by both the observer and observee and that at least one observation is completed for teaching staff on an annual basis. The College should update the Performance Management Review Form for teaching staff so that it includes a section to assess performance based on findings from observations. We identified on discussion with the Director of Human Resources that each member of teaching staff should undergo at least one observation every year. The Teaching Observation Forms, once completed, should also be signed off by the observer and observee. However, from a sample of 20 members of teaching staff selected, we identified the following issues: One Teaching Observation Form was not provided during the time of the audit as it could not be found; Only one of the 19 Teaching Observation Forms inspected were signed off by both the observer and observee; and Three of the 19 observation forms that we inspected had not been completed within the last year. We also identified that the Performance Management Review Form does not include a section to assess performance based on findings from observations. There is a risk that if there are any members of teaching staff that are underperforming, this would not be identified in a timely manner. There is also a risk that observation forms are not being fully completed and that observees are not receiving and benefitting from feedback. Management Response Following extensive research across the FE sector and within the college, we have reviewed our lesson observation scheme and as a result, will not be completing a graded observation for every member of teaching staff in 2015/16. This therefore supersedes the recommendation above. Our revised observation scheme risk assesses and focuses observation on new staff or staff who had a session judged adequate or unsatisfactory last year. This will be reviewed again for 2016/17. Where a graded observation is undertaken, we will check that the forms are correctly signed and will return forms where this is not the case. With these changes, it may not be necessary to review the PMR Form for teaching staff and this should be considered when the form is reviewed. Responsibility/ Deadline VP(C&Q) Immediate 2015 Deloitte LLP 10

14 2.5 Linking Individual Objectives to Department/College Objectives Low Priority Recommendation Rationale Priority It is recommended that the Performance Review Form is updated to clearly show the link between an individual s objectives and the relevant department/college objectives. The College may consider tailoring the example objective setting form we have included at Appendix E. We identified that the Performance Review Form records the agreed target date of staff objectives along with how these will be achieved and measured, however, it does not record which departmental/college objective that the staff member s objective is in support of. There is a risk that the achievement of departmental/college objectives may be hindered if staff are not also working towards them. Management Response The College recognises the current processes are cumbersome and difficult due to technology restrictions which makes accessing the system extremely slow. The policy and process will be reviewed and updated within the next 6 months to make the process easier to use and more effective for managers and colleagues. Responsibility/ Deadline Head of HR May Deloitte LLP 11

15 Appendix A Reporting Definitions Audit Assurance We have four categories by which we classify internal audit assurance over the systems we examine: Full, Substantial, Limited or None which are defined as follows: Assurance Level Evaluation and Testing Conclusion The controls tested are being consistently applied. There is a sound system of internal control designed to achieve the system objectives. There is evidence that the level of non-compliance with some of the controls may put some of the system objectives at risk. While there is a basically sound system of internal control, there are weaknesses, which put some of the system objectives at risk. The level of non-compliance puts the system objectives at risk. Weaknesses in the system of internal controls are such as to put the system objectives at risk. Significant non-compliance with basic controls leaves the system open to error or abuse. Control is generally weak leaving the system open to significant error or abuse. The assurance gradings provided here are not comparable with the International Standard on Assurance Engagements (ISAE 3000) issued by the International Audit and Assurance Standards Board and as such the grading of Full Assurance does not imply that there are no risks to the stated control objectives. Grading of Recommendations In order to assist management in using our reports, we categorise our recommendations according to their level of priority as follows: Priority Level Definition Recommendations which are fundamental to the system and upon which the organisation should take immediate action; Recommendations which, although not fundamental to the system, provide scope for improvements to be made; and Recommendations concerning issues which are considered to be of a minor nature, but which nevertheless need to be addressed Deloitte LLP 12

16 Appendix B Staff Interviewed Kay Leigh Nicola Walker Hazel Gunter Director (Human Resources and Organisational Development) HR Administration Assistant PA to Vice Principal (Resources & Financial Planning) 2015 Deloitte LLP 13

17 Appendix C Terms of Reference Internal Audit: Staff Performance Management Commencement: 17 March 2015 Budget: 5 days Auditor: Lauren Parsons Key contact(s): Kay Leigh Director of Human Resources Agreed with: Kay Leigh Director of Human Resources Report distribution: Draft Report: Principal Vice Principal, (Resources and Financial Planning)/Director of Finance Governance Officer Responsible Officer(s) Final report: Audit Committee Principal Vice Principal, (Resources and Financial Planning)/Director of Finance Governance Officer Responsible Officer(s) Introduction This internal audit forms part of the delivery of the approved internal audit plan for 2014/15. Objectives The internal audit will assess the adequacy and effectiveness of internal controls in operation. Weaknesses and unnecessary controls will then be brought to the attention of management and advice issued on how particular problems may be resolved and controlled. The internal audit will seek to provide reasonable assurance over the following areas: Staff performance management policies and procedures have been established and communicated to all relevant members of staff; Roles and responsibilities for staff performance management have been established; There is a performance management framework in place for staff including standard objective setting and appraisal forms; There is a formal feedback process in place; Staff objective setting, appraisal meetings and sign off of appraisal forms have been completed on a timely basis; Management are able to identify whether all appraisals and the associated paperwork have been completed; Individual s objectives are clearly linked to the College s strategic objectives; Sign off of a probation period is carried out on a timely basis and after the performance of the individual has been formally considered and agreed by management; and A process is in place for addressing underperformance issues and this process is followed where necessary. Meetings The internal audit will include meetings with four members of staff to identify their opinions on the effectiveness of the staff performance management system. Methodology The internal audit work will be carried out by discussion with appropriate staff, review of documents and testing, as necessary, to confirm the effectiveness of the controls in place. The internal audit shall be carried out with due awareness of the risks of fraud and corruption in the processes under examination however it 2015 Deloitte LLP 14

18 cannot be relied on to identify all fraud and corruption risks. When the internal audit work has been completed, the findings and any recommendations made will be discussed at a pre-arranged exit meeting. Reporting A draft report will be issued within 15 working days from the exit meeting to which the auditee will be asked to formally respond. A final report will be issued when all responses have been received and any outstanding issues addressed Deloitte LLP 15

19 Appendix D Meaning of the SMART Acronym We have documented below an example of the meaning of the SMART acronym. S M Specific state exactly what you want to accomplish (consider who; what; where; when) Measurable - how will you demonstrate and evaluate the extent to which the objective has been achieved? A R Achievable objectives should be achievable Realistic objectives should be realistic within the availability of resources, knowledge and time. T Timely - objectives should have a defined timeframe 2015 Deloitte LLP 16

20 Appendix E Example Objective Setting Form We have included below an example individual staff objective setting form with the College may consider tailoring to fit its own needs. College Objective Individual Objective 1: The key tasks needed to achieve your objective Date(s) for completion How will we measure a successful outcome? College Objective Individual Objective 2: The key tasks needed to achieve your objective Date(s) for completion How will we measure a successful outcome? College Objective Individual Objective 3: The key tasks needed to achieve your objective Date(s) for completion How will we measure a successful outcome? 2015 Deloitte LLP 17

21 Appendix F Statement of Responsibility We take responsibility for this report which is prepared on the basis of the limitations set out below. The matters raised in this report are only those which came to our attention during the course of our internal audit work and are not necessarily a comprehensive statement of all the weaknesses that exist or all improvements that might be made. Recommendations for improvements should be assessed by you for their full impact before they are implemented. The performance of internal audit work is not and should not be taken as a substitute for management s responsibilities for the application of sound management practices. We emphasise that the responsibility for a sound system of internal controls and the prevention and detection of fraud and other irregularities rests with management and work performed by internal audit should not be relied upon to identify all strengths and weaknesses in internal controls, nor relied upon to identify all circumstances of fraud or irregularity. Auditors, in conducting their work, are required to have regards to the possibility of fraud or irregularities. Even sound systems of internal control can only provide reasonable and not absolute assurance and may not be proof against collusive fraud. Internal audit procedures are designed to focus on areas as identified by management as being of greatest risk and significance and as such we rely on management to provide us full access to their accounting records and transactions for the purposes of our audit work and to ensure the authenticity of these documents. Effective and timely implementation of our recommendations by management is important for the maintenance of a reliable internal control system. Deloitte LLP Cardiff October 2015 This document is confidential and prepared solely for your information and that of other beneficiaries of our advice listed in our engagement letter. Therefore you should not, refer to or use our name or this document for any other purpose, disclose them or refer to them in any prospectus or other document, or make them available or communicate them to any other party. If this document contains details of an arrangement that could result in a tax or National Insurance saving, no such conditions of confidentiality apply to the details of that arrangement (for example, for the purpose of discussion with tax authorities). In any event, no other party is entitled to rely on our document for any purpose whatsoever and thus we accept no liability to any other party who is shown or gains access to this document. In this document references to Deloitte are references to Deloitte LLP. Deloitte LLP is a limited liability partnership registered in England and Wales with registered number OC and its registered office at 2 New Street Square, London EC4A 3BZ, United Kingdom. Deloitte LLP is the United Kingdom member firm of Deloitte Touche Tohmatsu Limited ( DTTL ), a UK private company limited by guarantee, whose member firms are legally separate and independent entities. Please see for a detailed description of the legal structure of DTTL and its member firms Deloitte LLP 18