Lease Car Policy and Procedure. Date Version Number Planned Review Date. Version 4 Addition of Appendix C

Transcription

1 Lease Car Policy and Procedure Policy Code PtHB / HR003 Date Version Number Planned Review Date June 2005 December 2010 May 2011 July 2011 September 2011 Version 3 Version 4 Addition of Appendix C July 2014 Document Owner Approved by Date Assistant Director Executive Committee July 2011 WF&OD Bwrdd Iechyd Addysgu Powys yw enw gweithredol Bwrdd Iechyd Lleol Addysgu Powys Powys teaching Health Board is the operational name of Powys teaching Local Health Board Page 1 Review Date: July 2014

2 Powys teaching Health Board (PtHB) Lease Car Policy and Procedure Contents Page Appendices Validation & Ratification 3 1 Introduction 5 2 Benefit in Kind Liabilities 6 3 Applying for a Car The Calculation of Private Charges 9 5 Conditions of Use Termination Charges 13 7 Additional Nominated Drivers 13 8 Return of the Vehicle A Car B Car C Lease Car Receipt 20 Page 2 Review Date: July 2014

3 VALIDATION & RATIFICATION To be completed by the Author no policy, procedure or guidance will be accepted without completion of this section which must remain part of the policy Title: Author: Lease Car Policy and Procedure Assistant Director of WF & OD Directorate: Workforce and Organisational Development Approved for submission by: Amanda Smith Date: July 2011 EVIDENCE BASE Are there national guidelines, policies, legislation or standards relating to this subject area? If yes, please include below: National guidelines and legislation If No, please provide information on the evidence/expert opinion upon which the policy has been based. CONSULTATION Please set out the arrangements undertaken and stakeholder groups involved in the development and consultation process: Reviewed and amended by Myra Morris PRG meeting 18/05/2011 Circulated for consultation to management Groups 1, 2 and 3, staff side and Intranet for wider consultation 18/05/2011 PRG meeting 13/07/2011 Executive Committee IMPLICATIONS Please state any training implications as a result of implementing the policy / procedure. Please state any resource implications associated with the implementation. Please state any other implications which may arise from the implementation of this policy/procedure. Page 3 Review Date: July 2014

4 Equality Assessment Statement TO BE COMPLETED Please complete the following table to state whether the following groups will be adversely, positively, differentially affected by the policy or that the policy will have no affect at all Equality Statement No impact Adverse Deferential Positive Comments Age Disability Gender Race Religion/Beliefs Sexual Orientation Welsh Language Human Rights Risk Assessment Are there any risks arising from the implementation of this policy? Do you believe that they are adequately controlled? Page 4 Review Date: July 2014

5 1 Introduction General Whitley Council Section 24 Part IV introduced the principle of making official vehicles available for private use in return for a private use contribution from the vehicle holder. PtHB has made a decision to review the current policies previously in place by Dyfed/Powys HA, Dyfed/Powys LHG and Powys NHS Trust; this policy replaces any previous policies in place for lease cars. The aim of the policy is to be fair and consistent to all individuals and assist PtHB in providing the day to day Service Care to the population of Powys. 1.2 PtHB, in determining the way in which these charges were to be calculated wished to abide by the following key principles: All staff could apply for a leased vehicle if they so wished (PtHB however reserves the right to refuse an application on reasonable grounds). It is important that where a lease car is considered, it is against the post, as official mileage plays a key part in the cost of the lease. The calculation of the private use charge is to be based solely on the number of business miles travelled and not where the individual travels to. There should be no incentives or penalties tied to the scheme with free access in or out of it (except for early termination charges on lease agreements). The choice of vehicle would be left to the driver, but PtHB retains the right to ensure that the lease vehicle meets the Green criteria both in emissions and cc of the vehicle. PtHB s liability will be restricted to the total cost that would have been incurred had the individual used their own car and been paid average travel expenses under A4C and Whitley Terms and Conditions for Standard users. The scheme should be simple to understand. 1.3 The operation of the scheme is governed by the Consumer Credit Act and PtHB is licensed under the Act. 1.4 The information contained in this policy is subject to changes in legislation. Staff should be aware that a lease car is considered to be a company car and remains the property of PtHB during the period of the lease. It will therefore be subject to taxation as a benefit in kind. Please contact your tax office for further information. 1.5 This policy applies to all grades of staff within PtHB including directors, board members and medical and dental officers. PLEASE NOTE for staff transferring into PtHB and bringing their lease car with them. A Novation Agreement MUST be in place before the vehicle can be accepted. Without this agreement in place, the vehicle CANNOT be covered by our insurance. 1.6 The individual will be responsible for supplying a full copy of his/her driving licence including details of any convictions/penalty points on an annual basis. This includes full details as above on any subsequent nominated authorised drivers Page 5 Review Date: July 2014

6 2 Benefit in Kind Liabilities 2.1 Taxation The Government has introduced new legislation regarding the taxation of company cars. From 6 th of April 2002 the taxable liability of a company car will be determined by its carbon dioxide (CO 2 ) emission. Prior to 6 th of April 2002 the taxable benefit was based on the business mileage of the vehicle. The new legislation is introduced in an effort to encourage selection of cleaner and more fuel-efficient vehicles. This information is subject to change at anytime by the Inland Revenue. The tax liability is based upon a percentage of the car s list price graduated according to the level of the car s CO 2 emissions. The exact CO 2, which is measured in grams per kilometre, is rounded down to the nearest 5g/km Petrol Vehicles The minimum tax liability will be 10 per cent of the car s list price, with the maximum being 35 per cent. Details of the scale charge are listed in Table Diesel Vehicles The CO 2 emissions of a diesel vehicle are substantially lower than petrol vehicles. They do however emit other harmful pollutants; therefore to offset the benefit of lower CO 2 emissions the government will introduce a 3% tax levy. This will mean that the minimum taxation liability level for a diesel vehicle will be 13 per cent of its P11D value up to a maximum of 38 per cent. Table 2.1 CO 2 Scale Charges 120 or less 120 or less 120 or less 10* * * * * * * * * * * * * * * * * * * ** *** *** Page 6 Review Date: July 2014

7 Diesel Supplements * add 3 per cent if car runs solely on diesel ** add 2 per cent if car runs solely on diesel *** add 1 per cent if car runs solely on diesel **** maximum charge so no diesel supplement 3 Applying for a Car 3.1 Think Carefully! When an individual member of staff decides that they would like to apply for a lease car they should, in the first instance satisfy themselves of the following: They have read and understood the policy and appreciate the basis on which the vehicle is being made available including how the charge is made up (see Section 4 below) They appreciate that the vehicle is not available for any purpose other than PtHB business and their personal social domestic and pleasure use if appropriate while they remain an employee of PtHB (i.e. Not for hire and reward, racing, pacesetting or business use other than for PtHB) The leasing company will recover not only the cost of damage over and above normal wear and tear, but will also charge an early termination fee if appropriate. All contract quotations include annual insurance, servicing and maintenance, road fund licence (RFL) and breakdown recovery services They are prepared to care for the vehicle, ensuring it is regularly serviced by a manufactures approved agent and not subject it to abuse. They understand that any charges levied by the leasing company during or at the end of a contract relating to damage outside the companies fair wear and tear policy will be passed on to the driver They understand that the key determinate of the cost of a particular vehicle is the total contract mileage. You should not underestimate private mileage or overestimate business miles in order to either reduce the private contribution or to overstate the allowance due. Cars returning over contract mileage are charged for at a set rate per mile and these charges will be passed on where appropriate (driver or budget holder). This charge also applies to cars which are returned under contract for business mileage where the allowance has been calculated more favourably due to managers/employees overstating official mileage. It is important that both manager and employee agree on the realistic mileage for both official and private use before a lease car is formally considered They understand current legislation with regard to company car taxation. That is to say that the car is a benefit in kind and as such will attract national insurance contributions which is paid by the employer. Income tax is taken by the Inland Revenue by adjustment to the individuals tax code. Page 7 Review Date: July 2014

8 3.1.7 That the lease is a 3-year commitment That the lease vehicle remains the property of PtHB and will be required to return the car should the employment end for any reason. If part way through a lease the employee can request transfer to a new employer, provided that employer agrees to the transfer of ownership from PtHB and accepts all future liabilities to do with the lease. 3.2 If the individual decides that they want to proceed with a lease car application they should collect the following information: An estimate of annual business mileage undertaken for PtHB. This must be discussed with their manager as he/she will be asked to sign up to before they can have a car. (see appendix A part 4) An estimate of annual private mileage. This will include the journey to and from their normal workplace. The make, model, engine size, fuel type (petrol/diesel/duel fuel), number of doors, paint colour and type (solid/pearlescent/metallic) and any factory fit or dealer options they wish to have quoted for up to 3 cars. A copy of the full driving licence including any convictions or penalty points. 3.3 The applicant should submit this information on form CAR 1 (Appendix A) to their line manager who will be required to authorise the estimated business mileage as being correct. For reference the applicant should keep copies of the requested quotes made on form CAR2 (Appendix B). Managers should be aware that it is their duty to ensure that all business mileage estimates are realistic. Once the business mileage is authorised and a car ordered it cannot be varied. It is the principal determinate of the cost of the car to PtHB so it must be accurate. Where there are known factors that will affect business mileage over the three years of the contract these should be taken into account and an average annual mileage determined. 3.4 The Line Manager is responsible for submitting the authorised form and budget code to the Lease Car Officer in the HR Operations Department, Basil Webb Hall, Bronllys Hospital, Bronllys, Brecon, Powys LD3 OLU who will obtain quotations for the selected vehicles at the stated mileage from a panel of approved leasing companies, the appropriate directorate signature of authorisation must be obtained before further processing can take place. 3.5 Once the authorised documentation has been received the Lease Car Officer will calculate the private use contribution using the formula detailed in section 4. A full quotation will be returned to the applicant who will have 14 days from the quotation date to accept one of the quotes by completing the appropriate forms regarding information on the chosen car, signing and returning the appropriate page to the Page 8 Review Date: July 2014

9 Lease Car Officer in HR Operations Department who will place the official order for the car. 3.6 If at any time between the acceptance of a quote and the placing of an order a change to the availability or specification of the chosen car occurs the Lease Car Officer will contact the applicant via and will require written agreement to any change in specification or cost before the order is placed. The acceptance of a quote does not bind PtHB to provide a car at the quoted specification or cost where it is unable to do so due to factors beyond its control (e.g. manufactures price increase, delivery delays or shortages of particular models). 3.7 Once the order has been placed, the Lease Car Officer will arrange the delivery of the car and notify the applicant/driver of a date. The driver will be responsible for receiving the car and inspecting it, bringing any concerns to the attention of the Lease Car Officer and delivery person immediately. The driver is required to sign the leasing companies delivery note and PtHB form CAR5 (Appendix C) accepting delivery, these forms should be forwarded to the Lease Car Officer and held on the appropriate lease car file for the individual. 4 The Calculation of Private Use Charges 4.1 Private use charges are calculated on the following basis: A B C D E F G H I J Annual leasing charge (excluding VAT and RFL) Plus PtHB administration charge for provision of car Plus Fuel reimbursement of driver for business miles Plus RFL Plus Insurance for business and private use Plus Employers national insurance contribution =Total Cost of the car (A+B+C+D+E+F) Less Travel expenses for stated business miles (average of L and L rates used in calculation) = The charge for private miles excluding VAT (G-H) Plus VAT K = Total annual contribution for private miles (I+J) Divided by 12 L = Monthly deduction from pay (K/12) Page 9 Review Date: July 2014

10 4.2 The administration charge of 95 is levied against each car. In this way the scheme could be self-financing in accordance with the number of cars within the fleet. 4.3 The current rates for road fund licence, fuel reimbursement, insurance, employers national insurance, administration charge and VAT are also detailed on a quotation. These are subject to review from time to time. 4.4 Once a quote has been accepted and the vehicle ordered the monthly charge will only change due to one or more of the following: Changes in road fund licence costs due to legislation. Insurance is renewed annually and any additional costs or savings are passed on to users. Changes in VAT. Changes in class 1A national insurance rates Changes in taxation banding on CO 2 emissions 5 Conditions of Use 5.1 Mileage Forms (General) The user is required to submit mileage forms on a monthly basis to the HR Payroll Department. This form is available from the Lease Car Officer. These forms must be completed in full, detailing milometer readings at the beginning and end of each month. Failure to submit forms on a monthly basis could lead to the withdrawal of fuel reimbursement until such time as the user has submitted the missing forms. It may also result in all mileage being classed as private use. 5.2 Study Leave Miles As with normal travel expenses, study leave miles should be shown separately. Although fuel for approved study leave is paid at the same lease car rate as for normal business it can be recharged to the study leave budget if appropriate. If a recharge to the study leave budget is required the appropriate budget code must be entered on the expenses form. Managers should note that certification of a form including study leave miles where the change is budget code details is not entered will mean an acceptance of the costs within normal budgets. 5.3 Business Miles Normal rules for assessing business mileages apply. The only exception to this being the journey to and from the nearest manufacturers authorised agent for normal servicing which can also be included as business miles (the Lease Car Officer will be responsible for assessing the reasonableness of such claims and as Page 10 Review Date: July 2014

11 a general rule the distance will be taken as the lesser of that from home or work to the garage using auto-route information). 5.4 Reimbursement of Official Mileage Reimbursement of official mileage will be in accordance with current HMRC rates. 5.5 Changes in Mileages Where a user experiences a change in their business use of the car and this is due to a change in their work beyond their control, PtHB will not adjust the private use charge. However PtHB reserves the right to limit its exposure to additional cost by reducing the total contract mileage of the car. A reduction in business miles is not an excuse to increase private mileage to compensate. Where private mileage has increased by more the 2000 miles per annum above that used to calculate the private use charge, PtHB can, if it wishes, increase the private use charges immediately by recalculation, using the original formula and any increased charges quoted by the leasing company. In any event PtHB will pass on at the end of the lease, those additional charges relating to over contract mileage caused by private usage. Please inform the lease car officer of any temporary situation which may affect business mileage e.g. maternity/adoption or long term sick Leave. 6Insurance The vehicle will be insured by PtHB for PtHB business, study leave and social/domestic and pleasure use only for as long as the user remains an employee of PtHB. Full details of the insurance policy in force will be circulated to users on renewal. This will include excess levels under the policy. Usually the policy will include a minimum policy excess which is the drivers liability and additional excesses for young, inexperienced drivers or those with previous convictions for traffic offences who are employed by PtHB. PtHB reserves the right to refuse applications from employees with a poor-driving record. On renewal any increase or decrease in premium will be passed on to users. The vehicle will not be insured for provisional licence holders. 5.7 Accidents As with any motoring accident the driver should ensure that he/she obtains full particulars (vehicle registration, make, colour, drivers name and address, driver s insurance policy number and company) from the other party/parties involved. Where possible they should also obtain the name and address of any witnesses and the name and number of any police officer who attends. At no time should they admit responsibility. Users should contact the identified officer responsible for processing all insurance claims for lease cars in the support services department of PtHB, who will advise them of the action to be taken. Approval to commence repairs can only be given by the appropriate support services officer. Usually where an accident takes place on PtHB business the PtHB will pay the excess on behalf of the individual providing there is no evidence of reckless or careless actions by the user. All damage to the vehicle must be notified to the appropriate support services Page 11 Review Date: July 2014

12 officer immediately. Failure to do so may frustrate an insurance claim and leave the driver liable to the full cost of repairs or end of contract charges. 5.8 Motoring Offences On application of a lease car the individual must supply a copy of the driving licence to the Lease Car Officer and details of any motoring convictions. It is the responsibility of the driver to ensure that, after these details have been submitted, any future convictions, for which points are awarded, are notified to the Lease car officer immediately. 5.9 Fixed Penalty Offences Any fixed penalty offences relating to the lease car will be the responsibility of the named driver. Where these offences may be the responsibility of another authorised nominated driver, it will be the responsibility of the named driver to ensure that the appropriate documentation is completed correctly and returned in the official envelope supplied with the minimum of delay. The driver will also be required to complete a return slip confirming that the appropriate action has been taken Travel Abroad Before travelling abroad with a lease vehicle, the employee will be required to notify the Lease Car Officer who will arrange details accordingly Wear and Tear Whilst it is acceptable that a vehicle is subject to reasonable wear and tear during its life the leasing company s interpretation of fair wear and tear is usually very closely drawn. Excluded are such things as: Glass Breakage (windows and lights) Punctures Kerbing damage to tyres and wheels Stone chipping where the paint is broken and rusting has started Scratches to paintwork and bumpers Holes left by the removal of mobile phones Stained, torn or cigarette burned upholstery Mechanical failure due to abuse or incorrect servicing Valetting of the car where proper care has not been taken. It is in the employee s interest to ensure that the above are fixed at the time they occur, either by arrangement with the Lease Car Officer, support services officer or at the time the car is serviced The PtHB can be invoiced for damages as listed in and where it is clear that they are the result of private use, careless business use or a failure to properly care for the vehicle these charges will be passed to the user. All damage to the vehicle must be notified immediately to the support services Page 12 Review Date: July 2014

13 officer. Failure to do so may frustrate an insurance claim and leave the driver liable for the full cost of repairs or end of contract charges. 6 Termination Charges In making a vehicle available for private use by an individual, PtHB does so on the understanding that the user will keep the vehicle for the 3 year contract term. Under certain circumstances the vehicle may become surplus to requirements before the end of the lease and will need to be returned to the leasing company early. In such cases it is normal for leasing companies to make an early termination charge to reflect its increased costs. PtHB will recharge the individual with early termination costs if the termination is due to factors within the employee s control. Reasons for early termination and who will pay are as follows: 6.1 PtHB to bear costs in the case of: Ill health retirement. Redundancy. Early retirement for reasons of service efficiency. Transfer to duties not requiring/or reduced travelling brought about by management. Dismissal 6.2 User to bear costs in the case of: Voluntary resignation of posts for any reason (including new appointment). Voluntary termination/handing back of vehicle before the end of the lease contract. (NOTE: For users who apply internally for a post not requiring travel it is the responsibility of the employee and appointing officer to negotiate arrangements surrounding an existing lease car. These should however be agreed in writing before confirmation of appointment by the Director of Workforce and OD, and copied to the Lease Car Officer.) 7 Additional Nominated Drivers The driver can nominate additional drivers who hold a full driving licence to use the vehicle, where this is a requirement each named, additional driver will be expected to provide details of their full driving licence and convictions to the Lease Car Officer, who will authorise the application. PtHB reserve the right to refuse any such requests. For drivers under the age of 25, special consideration will be given by the Lease Car Officer. 8 Return of the Vehicle months prior to the due return date the driver will be contacted by the Lease Car Officer to ascertain their intentions with regard to renewal or withdrawal from the scheme. Page 13 Review Date: July 2014

14 8.2 The Lease Car Officer will arrange with the driver for the vehicle collection at the end of the lease period. The driver must inspect the car with the collecting agent and any damage must be identified on the inspection form provided, to the satisfaction of the driver and sign for the acceptance of the inspection. Failure to do so will result in the driver being responsible for any return charges being made by the leasing company. (If you require any further information or advice please contact the support services officer prior to collection date) The milometer reading must also be entered on the collection sheet and appropriate return vehicle report form supplied by the collecting agent. This will form the basis of the assessment of the drivers/pthb s liability with regard to claims under the fair wear and tear policy of the leasing company so it is vital that the vehicle is returned in a clean and tidy condition. 8.3 If for whatever reason the employee is dismissed or the contract of employment ended the employee will be required to return the car immediately as part of PtHB property. On return of the vehicle please ensure that identification is sought from the collecting agent before you hand over car, documentation and keys and a signed termination document is received as a form of receipt. Page 14 Review Date: July 2014

15 Form Car1 Appendix A APPLICATION FOR LEASED VEHICLE 1 EMPLOYEES UNDERTAKING 1.1 I wish to apply for a leased vehicle under the terms of the Lease Car Policy of PtHB. I have read and understood the policy and if I accept a quotation, I understand that I shall be bound to keep the vehicle for the term of the lease. I also undertake to ensure that the vehicle will be properly maintained in line with the manufacturer requirements. 1.2 Should I leave PtHB for any reason before the end of the lease period I understand that my liability for termination charges will be governed by the provisions in section 6 of the policy and I will be required to hand back the vehicle with immediate effect. 1.3 I have discussed my future business mileage with my line manager, these are believed to be the realistic mileage for this post and we know of no reason why this should change in the immediate future. I understand that PtHB shall have the right to suspend petrol reimbursement if I fail to provide travel claims on regular basis. 1.4 The Estimated Business miles per annum for this post are miles My Estimated Private miles per annum are The estimated total miles per annum are miles miles 1.5 I attach 3 requests for quotations for vehicles on the basis of the mileage shown above and understand that the quotations provided by you will only be valid for a period of 14 days from date of issue. My written acceptance of a quotation as defined in section 3.5 of the policy will be taken as authorisation to order the vehicle. 1.6 I understand that once the order has been placed I accept all my responsibility under the policy. Should I wish to cancel my order before the vehicle has been delivered I authorise PtHB to deduct any cancellation charge levied by the leasing company from my pay. Page 15 Review Date: July 2014

16 Appendix A contd. 2 APPLICANT DETAILS Name: Job Title: Department: Line Manager: Staff No.: Nat. Ins. No.: Address: Work Tel: Mobile No: address Home Tel: 2.1 NOMINATED DRIVERS (including main driver) Name D.O.B. Relationshi p to Applicant Driving Licence No. Date Passed Test if in the last 5 years Full current UK Driving Licence Yes/No* Yes/No* Yes/No* Yes/No* *Delete as appropriate. You are required to advice the Lease Car Officer if you hold a licence other than UK. PLEASE PROVIDE A COPY OF THE FULL DRIVING LICENCE FOR EACH OF THE ABOVE-NOMINATED DRIVERS, INCLUDING THE MAIN DRIVER. ( PHOTO CARDS ALONE WILL NOT BE ACCEPTED) Page 16 Review Date: July 2014

17 3. Employee Declaration Appendix A cont d. 3.1 I have read and understood the policy, in particular my responsibilities outlined in section 3.3 with regard to mileage estimates. The business mileage applied for is accurate to the best of my knowledge and includes only those miles for which travel expenses would normally be payable. 3.2 I understand that should my employment end at any time during the lease that I will be required to return the car with immediate effect and may be subject to termination fees. Signed: Name (print): Date: 4 MANAGERS AUTHORISATION 4.1 I have read and understood the policy, in particular my responsibilities outlined in section 3.3 with regard to mileage estimates. The business mileage applied for is accurate to the best of my knowledge and includes only those miles for which travel expenses would normally be payable. 4.2 I can confirm that the employee currently holds a contract of employment that shall remain in force for the period of the 3 year lease and should that contract end the car must be returned with immediate effect as part of the property of PtHB 4.3 Managers signature: Name (please print): Employee s Budget Code Position: Date: 5. Directorate/ General Manager Approval: Director/General Manager Signature: Name (please print) Date: Where approval is not given, the Locality Manager/Director is responsible for advising the manager of the reasons for refusal. Page 17 Review Date: July 2014

18 Form Car2 Appendix B PtHB Requested Vehicle Quotations 1. Make: Model: Specification: Engine: Petrol/Diesel/LPG* No. of Doors: Saloon/Hatchback/Estate/Other * Colour: Solid/Metallic/Pearlescent * Options Required: NOTE: * Delete as appropriate 2. Make: _ Model: Specification: Engine: Petrol/Diesel/LPG* No. of Doors: Saloon/Hatchback/Estate/Other * Colour: Solid/Metallic/Pearlescent * Options Required: Page 18 Review Date: July 2014

19 Appendix B cont. 3. Make: Model: Specification: Engine: Petrol/Diesel/LPG* No. of Doors: Saloon/Hatchback/Estate/Other * Colour: Solid/Metallic/Pearlescent * Options Required: NOTE: * Delete as appropriate The above quotes have been provided using the following mileages:- MILEAGES Business miles: Private miles: Total miles: The above quotations are invalid if any of the above mileages are incorrect. You must notify the lease car officer immediately with any changes. We recommend that you visit a dealer in order that you can give as much detail as possible to ensure that the quoted vehicles meet your requirements and expectations. Page 19 Review Date: July 2014

20 Appendix C LEASE CAR RECEIPT Car Registration Number 1 I can confirm that I have accepted delivery of the above lease Car together with the following: - Two sets of Keys Manufacturers Handbook Manufacturers Service Book Spare Wheel/Tyre (delete where not applicable) Tool Kit Mileage on delivery Signature of Delivery Agent Name (please print) I understand that the car is being used in accordance with PtHB Lease Car Policy, and that i will be required to keep the vehicle for the full period of the lease unless PtHB agree to an early termination as detailed in Section 6 of the policy. I agree to ensure that the vehicle is maintained in accordance with the manufacturer s service schedule. I also agree to care for the vehicle and ensure that the Support Services Officer is notified immediately should it be damaged in any way. Signed Name Address Designation Staff Number Page 20 Review Date: July 2014