PENSIONS ROUND-UP january 2016 IN THIS ISSUE. 08 Case Law. 02 Introduction. 09 Other News. 03 DC Flexibilities. 04 The Pensions Regulator

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1 PENSIONS ROUND-UP january 2016 IN THIS ISSUE 02 Introduction 03 DC Flexibilities 04 The Pensions Regulator 05 Department for Work and Pensions 08 Case Law 09 Other News 10 On the Horizon 11 Contact Details 07 Legislation

2 INTRODUCTION Welcome to the latest edition of DLA Piper s monthly newsletter Pensions Round-Up in which we provide an overview of developments in pension legislation, case law and regulatory guidance. In this edition we look at key developments from January 2016 including the following. DC Flexibilities: an announcement about proposals to cap excessive early exit charges for those eligible to access the pension freedoms; statistics about flexible payments; and the FCA s response to the Work and Pensions Committee s report about guidance and advice. The Pensions Regulator: the Regulator s latest quarterly report about automatic enrolment compliance and enforcement activity; information about new questions in the DB scheme return from January 2016; and the publication of the Regulator s latest DC Trust data. Department for Work and Pensions: a consultation about technical changes to the automatic enrolment legislation including the introduction of further exceptions; information about the impact of the new State Pension on an individual s entitlement; the publication of a Work and Pensions Committee report about the pension statements being issued by the DWP; and a consultation on draft regulations to give effect to a ban on member-borne commission. Legislation: draft legislation in relation to the new State Pension; and the publication of draft regulations which, in light of the introduction of the tapered annual allowance, propose to add to the circumstances in which schemes have to provide pension savings statements. Case Law: a High Court judgment about assessing whether peripatetic workers are ordinarily working in the UK for the purposes of the automatic enrolment duties; and an update about an appeal from a Pensions Ombudsman determination relating to pension liberation. Other News: the publication by PASA of its first tranche of guidance about GMP reconciliation; a PPF publication about contingent assets and guarantor strength; the Public Accounts Committee s report about automatic enrolment; and the results of EIOPA s first stress test in relation to occupational pension schemes. On the Horizon: a timeline of some of the key future developments in pensions to help employers and trustees plan ahead. If you would like further information about any of the issues raised in this edition of Pensions Round-Up, please get in touch with Cathryn Everest or your usual DLA Piper pensions contact. Contact details are at the end of this newsletter. 02 Pensions Round-Up January 2016

3 DC FLEXIBILITIES EARLY EXIT FEES In July 2015 the Treasury published a consultation looking at barriers that may be stopping people using the new DC flexibilities. One of the areas considered was the prevalence of early exit charges and options to reduce such charges. Whilst the response to the consultation has yet to be published, on 19 January it was announced that the Government proposes to place a duty on the Financial Conduct Authority to cap excessive early exit charges for those eligible to access the pension freedoms. These proposals will form part of the response to the consultation and, in due course, the FCA will consult fully on setting the level of the cap. The Treasury announcement does not make specific reference to occupational pension schemes but the Minister for Pensions has indicated in a social media post that there will be a cap on exit penalties in trust-based pensions alongside the FCA cap for contract-based schemes. It will be interesting to see further detail about the proposals for the cap when the response to consultation is published but in the meantime, as an initial step, trustees might want to check whether any early exit charges currently apply in their scheme. FLEXIBLE PAYMENT STATISTICS On 27 January HMRC published an updated version of its statistics about flexible payments in order to reflect payments made in the fourth quarter of The statistics include that, in the fourth quarter, 123,000 payments were made and the number of individuals to whom flexible payments were made totalled 67,000. This takes the total number of payments since the flexibilities were introduced in April 2015 up to 374,000, the total value of which is 3,530 million. The data underpinning the figures comes from Real Time Information reports submitted to HMRC. However, at this stage, the figures are not comprehensive because reporting is optional for 2015/16. It will therefore be interesting to see how the figures vary once compulsory reporting applies from April FCA RETIREMENT INCOME MARKET DATA On 7 January the Financial Conduct Authority published retirement income market data for the period from July to September The areas covered by the report include choices made by consumers accessing their pensions, levels of pension withdrawals for customers making a partial withdrawal, use of regulated advisers, use of Pension Wise, and whether consumers change providers when accessing their pensions. Findings include that, of the 178,990 pensions that were accessed in the quarter, 34% were accessed using uncrystallised funds pension lump sums (both partial and full withdrawals), 30% used income drawdown (both partial and full withdrawals), 13% were used to purchase an annuity and 23% were full withdrawals using small pot lump sum payments of 30,000 and below. Further data will be published on a quarterly basis. RESPONSE TO WORK AND PENSIONS COMMITTEE The December edition of Pensions Round-Up included an article about the Government s response to the Work and Pensions Committee s Report in relation to its inquiry into the guidance and advice on offer to people navigating the DC flexibilities. On 8 January the FCA s response was published which includes that: (i) going forward, the FCA is collecting sales data for those customers who have accessed their pensions either as regular income or lump sum withdrawals and the data breaks down by pot size, age of consumer, whether the sale was advised, and the product options selected; and (ii) now that providers have had time to see the new freedoms bed in, the FCA is starting to see new products emerge and examples of automated advice models are starting to come on stream. In relation to risk warnings, the FCA reports that it has found that firms have put in place clear processes to deliver risk warnings although the format in which they are being delivered varies and it has identified examples of good, poor and non-compliant practice. The FCA has provided feedback to firms, where necessary, asking them to address its concerns on risk warnings. The FCA will continue to monitor this. 03

4 THE PENSIONS REGULATOR AUTOMATIC ENROLMENT COMPLIANCE On 28 January the Regulator published its latest quarterly bulletin on automatic enrolment compliance and enforcement activity covering the period 1 October to 31 December The Regulator states that there was a sharp rise in the number of statutory notices issued in this period, which reflects the rise in the numbers of employers with automatic enrolment duties and the changing employer type. Figures reported include that, in this period, the Regulator issued: 2,596 compliance notices (taking the total to 4,818); 78 unpaid contributions notices (taking the total to 224); 1,021 fixed penalty notices (taking the total to 1,594); and 24 escalating penalty notices (taking the total to 31). The bulletin also reports that: 221 reviews were completed, with 21 statutory notices confirmed and 200 revoked, substituted or varied; and 2 review decisions were confirmed by the Tribunal Service. DB AND HYBRID SCHEME RETURNS Trustees may find it useful to note that an example version of the scheme return for DB and hybrid schemes dated January 2016 is available on the Regulator s website. The example form highlights the questions that appear for the first time from January 2016 which cover issues including the following for DB schemes and sections: (i) questions about transfers of member benefits with these questions, the Regulator is seeking better to understand the level and nature of transfers, particularly those between DB and DC arrangements this year the information only has to be provided where it is known, but the Regulator states that it will be required for subsequent scheme returns; and (ii) in light of a new levy discount structure to be applied by the PPF to last man standing schemes, questions about whether legal advice has been obtained confirming whether the scheme is a last man standing scheme. DC TRUST On 28 January the Regulator published its latest DC Trust data which provides statistics on occupational DC trust-based pension schemes and memberships. The Regulator s accompanying press release reports that the data shows further evidence of market concentration in the largest DC schemes. Key findings include that: (i) DC schemes with 12 or more members account for 8% of the total universe of DC trust schemes but more than 98% of the memberships; (ii) the number of members has again increased significantly with 2.3 million new members; (iii) of the 6.9 million DC members of occupational schemes, around 70% have joined since automatic enrolment began; and (iv) of those members in schemes being used for automatic enrolment, 80% are in master trusts. WITHHOLDING TAX RECLAIMS The Regulator has added information to its website noting that UK occupational schemes may be asked by tax authorities in other EU member states to provide evidence in order to assist with overseas withholding tax reclaims, including that the scheme is an Institution for Occupational Retirement Provision (IORP) and that it is subject to regulation in the UK in accordance with the European IORP Directive. The Regulator states that it is unable to provide certification for individual schemes but it has added a letter to its website that can be provided to the relevant authority as part of a claim relating to a scheme with more than one member. OTHER CONSULTATIONS Two consultations were published by the Regulator in January, both of which close in February: (i) a consultation (issued as part of a Government-wide programme) on the Regulator s draft Innovation Plan which opens a debate with industry on how the Regulator can do more to integrate technology into the way it educates and enables the regulated community and explore new ideas such as a pensions dashboard for savers; and (ii) a consultation on the Regulator s draft prosecution policy which explains when and how the Regulator will use its prosecution powers. 04 Pensions Round-Up January 2016

5 DEPARTMENT FOR WORK AND PENSIONS AUTOMATIC ENROLMENT TECHNICAL CHANGES On 26 January the DWP published a consultation on draft regulations proposing changes to the automatic enrolment legislation. The DWP intends to publish the response to consultation in early March with a view to regulations following later in March and coming into force on 6 April The draft regulations include the introduction of further exceptions which will turn the automatic enrolment and re-enrolment duties into powers in relation to jobholders who hold office as a director of the company by which they are employed, and jobholders who are members of a Limited Liability Partnership but who are not employees for tax purposes. In both cases, it is proposed that opt in rights would be retained. The DWP proposes replacing the current position of two possible deadlines (depending on whether there are workers to re-enrol) for submitting the re-declaration of compliance with a single deadline which is five months after the third anniversary of the staging date or last re-enrolment date. In light of the upcoming abolition of contracting-out, an alternative DB quality requirement was introduced in 2015 based on the cost of future accrual. Currently this test must be applied at a benefit scale level but a transitional easement is proposed so that it can be applied at a scheme level for schemes which were contracted-out on 5 April 2016 and have not changed their benefits. The easement will apply until the earlier of the effective date of the first actuarial report on or after 6 April 2016 or 5 April These changes are intended to further simplify the automatic enrolment framework and ease the burden on employers and we would therefore expect them to be welcomed by employers. GUIDANCE ON THE ADVICE REQUIREMENT When the DC flexibilities were introduced in April 2015, the transfer legislation was also updated so that members who are converting or transferring safeguarded benefits in excess of a particular value in order to access flexible benefits must take independent advice before doing so. A common example of the type of transfer to which the advice requirement applies is a DB to DC transfer. However, the definition of safeguarded benefits is broader than DB and catches benefits which are not money purchase or cash balance benefits. In January the DWP published a factsheet summarising the principles for determining whether or not certain benefits with guarantees fall within the definition of safeguarded benefits and providing examples of benefits which are safeguarded, those which are not and those which may or may not be depending on the terms of the policy in question. NEW STATE PENSION PENSION STATEMENTS On 11 January the Work and Pensions Committee published an interim report as part of its Understanding the new State Pension inquiry setting out a number of changes which it recommends are made to the pension statements the DWP is issuing. Some recommendations relate to the fact that since November the DWP has included a Contracted Out Pension Equivalent amount (COPE) in statements to help those who have been contracted-out see how National Insurance contributions paid before 6 April 2016 will contribute to their overall pension income. The Committee reports that it has heard concerns that the inclusion of the COPE will tend to mislead and confuse and in turn increase the administrative burden on private pension trustees. However, on 18 January, the Minister for Pensions gave evidence to the Committee in which she stated that there has been a misunderstanding among the Committee of what the COPE is and that the recommendation that the amount be called the contracted-out deduction is not appropriate. More generally, the Minister reported on a new digital state pension statement service due to be introduced in the next few months. It is worth trustees being aware what the pension statements cover as members who receive a statement from the DWP may raise queries with the scheme about their contracted-out benefits. 05

6 DEPARTMENT FOR WORK AND PENSIONS NEW STATE PENSION IMPACT On 14 January the DWP published a report providing analysis about the effects of the new State Pension on an individual s pension entitlement. In the summary of key results, the report looks at the transition, the impact on individuals, the impact of specific features of the reform, and changes to means-tested benefit. A section of the report which looks at the specific feature of uprating of the new State Pension is of particular note for schemes which contain GMPs. The issue here is complex but, in summary, it relates to the fact that there is no requirement on occupational pension schemes to pay increases on GMPs which accrued prior to 6 April 1988 but the way that the additional State Pension is currently calculated can effectively mean that an amount is paid through the State Pension which can be virtually the same as if increases had been paid on the pre-1988 GMP. When the new single-tier State Pension is introduced and there is no additional State Pension, this arrangement will end which could lead to some people getting a lower notional outcome. However, the report notes two key factors that offset potential notional losses the triple lock and the ability to build up additional qualifying years in the new State Pension from 2016/17. The key point here for trustees is that scheme literature may reflect the existing position and refer to increases on pre-88 GMPs being paid through the State Pension. However, this will not be correct for those reaching State Pension age on or after 6 April 2016 and therefore trustees should review their scheme literature on this point. If you would like further information or advice on updating scheme literature, please get in touch with your usual DLA Piper pensions contact. FURTHER CONSULTATION ON COMMISSION On 26 January the DWP published the Government response to its October consultation about regulating to ban member-borne commission. The DWP is now consulting on draft regulations on this issue. Key points to note about the final proposals include the following. Subject to limited exceptions, the regulations will apply to occupational pension schemes that provide money purchase benefits (including where AVCs are the only such benefits) and are being used by an employer as a qualifying scheme for automatic enrolment in relation to at least one jobholder. The consultation considered two options placing a regulatory duty on trustees or on service providers. The Government has decided that the duty will be on service providers and will prevent them from levying a charge on members to recover the cost of commission payments to advisers. Service providers for these purposes include pension providers, bundled pension providers and third party administrators. The October consultation proposed including asset managers but the Government has not received any evidence that they are party to or facilitate commission payments or charges on members and therefore they are not included in the final proposals. Trustees will: (i) have a duty to inform service providers whether the scheme is being used as a qualifying scheme; (ii) if requested, have to provide information to the service provider about deferred members who should be covered by the ban; and (iii) have to confirm via the scheme return whether a service provider has confirmed its compliance (or not) with the ban. The draft regulations are proposed to come into force in April 2016 when the ban will apply to new commission arrangements and variations or renewals of existing arrangements. Later in 2016 the DWP will consult on regulations in respect of existing commission arrangements. Trustees should note the proposed role for them and may want to consider starting to engage with their service providers in relation to this issue and ascertaining the extent to which it affects their scheme. 06 Pensions Round-Up January 2016

7 LEGISLATION NEW STATE PENSION The following draft legislation was published in relation to the new State Pension during January. The draft State Pension (Amendment) Regulations 2016 which set the weekly amount of the full rate of the new State Pension at The draft Social Security (Contributions) (Amendment No.X) Regulations 2016 which were published by HMRC for information and technical comment. An accompanying Policy Paper explains that these regulations make amendments to reporting requirements because a consequence of the introduction of the new State Pension and the abolition of contracting-out is that employers will need to report less earnings information to HMRC when making Real Time Information returns. Changes are also being made to remove the need for employers to report the Scheme Contracted-out Number and Employer Contracted-out Number as they will no longer be needed once contracted-out contributions are abolished. ANNUAL ALLOWANCE CHANGES IMPACT ON INFORMATION REQUIREMENTS From 6 April 2016 the tapered annual allowance will apply to those who have an annual income over 110,000 and an adjusted income (which includes pension savings) of over 150,000. The taper will operate so that for every 2 of adjusted income over 150,000, the annual allowance will reduce by 1 to a minimum of 10,000. In light of this, on 27 January HMRC published draft regulations for technical consultation which make changes to the information requirements which apply to scheme administrators (that is, the administrator for Finance Act purposes, which may be the trustees). HMRC proposes to add to the circumstances in which scheme administrators must issue pension savings statements to members to include cases where the member s pensionable earnings for the tax year exceed 110,000. The draft Explanatory Memorandum states that the purpose of this is so that members have the information they need to determine whether or not they may be subject to the tapered annual allowance. From 6 April 2016 pension input periods will have to be aligned with tax years and for 2015/16 transitional provisions apply which, for annual allowance purposes, split the year into two mini tax years. In light of this, the draft regulations also propose some modifications to the pension saving statement requirements as they relate to the 2015/16 tax year. Trustees should be aware of the proposals and that, if they are enacted, administrative processes will need to be updated accordingly. IORP II DIRECTIVE In March 2014 the European Commission published proposals for revisions to the Directive on the activities and supervision of institutions for occupational retirement provision (IORP II Directive). Suggested amendments to the draft were subsequently published by the Council of the European Union. The next stage of the progress of the IORP II Directive took place in January when the Committee on Economic and Monetary Affairs voted to adopt an updated version of the Directive. Areas of change in the IORP II Directive include the funding requirement for cross-border schemes, the knowledge requirement for those running schemes and the introduction of annual Pension Benefit Statements for members, standardised at EU level. The action that will need to be taken by UK schemes will depend on the final form of the Directive and how it is transposed into national law but, for now, it is worth schemes being aware that the draft Directive continues to progress and that changes (for example, in relation to disclosure in light of the Pension Benefit Statement requirements) may be on the horizon. 07

8 CASE LAW AUTOMATIC ENROLMENT PERIPATETIC WORKERS Background One of the criteria that workers need to meet in order to fall within the scope of the automatic enrolment duties and the opt-in rights is that they are working or ordinarily work in the UK. The legislation does not define what is meant by ordinarily works although guidance from the Regulator states that the primary issue to be considered is where the worker is based. In late December a High Court judgment was issued which considers the meaning of the ordinarily works criterion. The case concerned seafarers who work on cruise ships. These seafarers live in the UK but during any particular tour of duty live on board the cruise ships to which they are assigned. All of the cruise ships spend a significant majority of their time outside UK territorial waters. There were two broad categories of worker under consideration, both of which the Regulator thought were caught by the duties. This judgment relates to a judicial review application by the employer. Category 1: workers who habitually join and leave the cruise ship at a port within the UK. Category 2: workers who begin and end tours of duty at ports outside the UK but days spent travelling to and from the ship are treated as days of work for the purposes of entitlement to pay and leave. The court s conclusions In summary, the court concluded that workers in category 1 could be regarded as ordinarily working in the UK but workers in category 2 could not. In relation to category 2, the court stated that a key question in determining where a peripatetic worker is based is where their tours of duty begin and end. The court noted that the sample contracts relied on in evidence make it clear that each tour of duty starts when the worker joins the ship and ends when they leave the ship. The court regarded it as understandable that the travel days for category 2 workers are paid and not counted as leave, but took the view that on those days they are not working but are commuting to and from the place where they begin and end their work. On 12 January the Regulator issued a press release in relation to the judgment stating that it confirms that the position taken in its guidance and in determining cases in relation to peripatetic workers is correct and that when establishing where the person ordinarily works the base test, not the contract test, is the appropriate test to apply. (In summary, the base test involves looking at how the contract is in fact being operated and the contract test involves looking at the terms of the contract when it was made.) This judgment is useful both in seeing the general approach the court took by applying the base test and how this was applied to the particular categories of worker in question. However, this is a complex area and cases will turn on their own facts and therefore we suggest that employers with peripatetic workers consider seeking advice about the application of the automatic enrolment duties. PENSION LIBERATION BLOCKED TRANSFERS A number of determinations have been issued by the Pensions Ombudsman Service since December 2014 relating to the issue of pension liberation. One category of complaint is blocked transfers, that is, cases where schemes refuse to make transfers because they suspect that the proposed receiving scheme may be involved with pension liberation. A determination by the Pensions Ombudsman dated 30 June 2015 in which he rejected a member s complaint that her pension provider had refused to allow a transfer is currently the subject of an appeal to the courts. It is useful for trustees to be aware of this case because its outcome may impact how schemes approach transfer requests. Court listings indicate that the hearing took place on 18 January but, as at the end of January, it was not known when the judgment will be issued. 08 Pensions Round-Up January 2016

9 OTHER NEWS GMP RECONCILIATION In January the Pensions Administration Standards Association (PASA) released its first tranche of guidance for schemes on GMP reconciliation, which comprises: (i) a call to action for trustees and scheme administrators setting out ten reasons to reconcile membership and GMP data with HMRC; (ii) a GMP reconciliation process map; (iii) guidance on first steps in data reconciliation; (iv) guidance about member level reconciliation; and (v) guidance about the role of tolerances in reconciliation and rectification exercises. The second phase of guidance will follow in February. GMP reconciliation is one of the tasks schemes should consider in connection with the end of contracting-out, and therefore to the extent that schemes are not already looking at this issue, they should consider registering with HMRC s Scheme Reconciliation Service (expressions of interest have to be sent before 5 April 2016) and developing an action plan. PPF CONTINGENT ASSETS Trustees who are putting in place contingent assets for the purposes of the 2016/17 levy may be interested to note that, in January, the PPF published a briefing note entitled Contingent Assets. Guarantor Strength. The note reflects the PPF s experience of the contingent asset review process and highlights particular issues for trustees to be aware of but does not replace the PPF s Levy Rules and Guidance for 2016/17. The PPF reports that the note is substantially unchanged from the January 2015 version except in relation to references relevant to the 2016/17 levy year. PARLIAMENTARY COMMITTEES On 13 January the Work and Pensions Committee launched an inquiry on intergenerational fairness. The inquiry will investigate the extent to which disparity identified between those born between 1956 and 1961 and younger generations is a consequence of government policies, such as the triple lock on State Pension increases. The Committee intends to take a view on the long-term viability of policy measures such as the triple lock in the context of financial pressures on younger groups. On 27 January the Public Accounts Committee published a report in relation to its automatic enrolment inquiry. The Committee found that the DWP has successfully implemented automatic enrolment for larger employers but the real test is still to come as smaller employers enrol staff between 2016 and Recommendations in the report include that: (i) the DWP should report to the Committee in 12 months on the scope and progress of its planned review of automatic enrolment, factoring in wider reforms and the potential impact on retirement incomes; and (ii) the DWP should set out a clear timetable to clarify how smaller pension pots are to be treated. EIOPA S STRESS TEST In May 2015 the European Insurance and Occupational Pensions Authority (EIOPA) announced the launch of a pensions stress test, the objectives of which included to test the resilience of DB and hybrid schemes against adverse market scenarios and increased life expectancy. On 26 January EIOPA published the results of the stress test which include that: IORPs are relatively more resilient to an increase in longevity than to market adverse scenarios; and absorption of these shocks depends heavily on the time element for realising liabilities and the mitigation and recovery mechanisms in place in each country. Also on 26 January, the Pensions Regulator issued a press release responding to the report in which it stated that it strongly endorses the conclusion that the flexibilities within the UK pensions sector mean there is only a limited link between pension schemes and financial stability. 09

10 ON THE HORIZON DATE Unknown Autumn 2015 Early 2016 DEVELOPMENT A consultation on revised regulations about equalising GMPs is expected in this Parliament. The reforms in relation to Defined Ambition, Collective Benefits and automatic transfers of small DC pots will be revisited once the market has had time and space to adjust to the other reforms underway. A draft updated IORP Directive is under consideration. The current draft states that Member States would have 18 months after the Directive comes into force to transpose provisions into national law. Further developments were expected on proposals for transparency of costs and charges. A response to an October consultation about consequential amendments relating to the end of contracting-out will be published, which will also provide an update on the Reference Scheme Test underpin issue. The date for consultations on other aspects of the legislation is not known. A final response is expected from the Board of the UK Statistics Authority in relation to the June consultation on consumer price statistics. The Government response to its consultation on exit charges and the transfer process is expected to be published The Regulator intends to review its guidance on transfers. The Regulator intends to publish guidance on DB scheme investment strategy. 16 March 2016 The Government will respond to its consultation on reforming pensions tax relief in the Budget April 2016 The reform of State Pension and the end of contracting-out will take effect. July 2016 End of 2016 April 2017 The tapered annual allowance is due to be introduced. The lifetime allowance is due to fall to 1 million and transitional protection (fixed protection and individual protection) is expected to be introduced. It is proposed that member-borne commission payments and Active Member Discounts will be banned from DC qualifying schemes. The commission ban will initially apply to new arrangements, and to existing arrangements later in Miscellaneous amendments consequential on the DC flexibilities (currently the subject of consultation) are expected to come into force including requirements for trustees to issue retirement risk warnings to members with flexible benefits. Technical changes to the automatic enrolment legislation, including the introduction of further exceptions, are proposed to come into force. An updated version of the DC Code (currently subject to consultation) is expected to come into force. Consultation on supporting guidance is expected in spring The transitional period in which employers and schemes may continue to use the VAT treatment in VAT Notice 700/17 ends on 31 December Legislation to enable the development of a secondary annuities market is expected to be introduced. Consultations on the detail of the proposals are expected in The measures on DC charges and governance standards will be reviewed. 6 April 2018 The lifetime allowance is due to be indexed annually in line with CPI. 10 Pensions Round-Up January 2016

11 CONTACT DETAILS Cathryn Everest Professional Support Lawyer, London T +44 (0) cathryn.everest@dlapiper.com David Wright Partner, Liverpool T +44 (0) david.wright@dlapiper.com Vikki Massarano Partner, Leeds T +44 (0) vikki.massarano@dlapiper.com Claire Bell Partner, Manchester T +44 (0) claire.bell@dlapiper.com Ben Miller Partner, Liverpool T +44 (0) ben.miller@dlapiper.com Tamara Calvert Partner, London T +44 (0) tamara.calvert@dlapiper.com Kate Payne Partner, Leeds T +44 (0) kate.payne@dlapiper.com Michael Cowley Partner, London T +44 (0) michael.cowley@dlapiper.com Matthew Swynnerton Partner, London T +44 (0) matthew.swynnerton@dlapiper.com Jeremy Harris Partner, Manchester T +44 (0) jeremy.harris@dlapiper.com 11

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