DISCIPLINARY COMMITTEE OF THE ASSOCIATION OF CHARTERED CERTIFIED ACCOUNTANTS

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1 DISCIPLINARY COMMITTEE OF THE ASSOCIATION OF CHARTERED CERTIFIED ACCOUNTANTS REASONS FOR DECISION In the matter of: MR WARREN ROBERT DELO Heard on: 7 & 8 January 2015 Location: Committee: Legal Adviser: Persons present and capacity: Observers: ACCA Offices, 29 Lincolns Inn Fields, London, WC2A 3EE Mr Chris Chapman (Chairman), Mr Graeme Patrick (Accountant) and Mr Robin Hay (Lay) Ms Valerie Charbit Ms Cawley-Wilkinson (ACCA Case presenter) and Ms Lucy Annetts (Committee Officer) None PRELIMINARY APPLICATIONS/SERVICE OF PAPERS 1. The Committee convened to consider two allegations against Mr Delo. 2. The Committee had before it a bundle of papers numbering 1-390, service bundles numbering 1-31 and additional tabled papers numbering Mr Delo applied to have the further tabled papers admitted. The Committee allowed the tabled evidence to be admitted since it was short and there was time before the hearing to read the additional papers. 4. Mr Delo attended the hearing but was not represented. ALLEGATIONS/BRIEF BACKGROUND 5. Mr Delo was liable to disciplinary action in respect of two allegations. Allegations one and two alleged misconduct in the alternative to a breach of Global Practising Regulation 3(2)(a) and 3(2)(b). 6. Regulation 3(2) of the Global Practising Regulations require a member who is a director or partner of a firm where public practice is carried on in the name of the firm to hold a practising certificate; (regulation 3(2)(a)). It also 1

2 requires a member who holds rights in a firm where public practice is carried out to hold a practising certificate; (regulation 3(2)(b)). 7. Allegation 1(b) refers to Mr Delo holding the position of director or member of a limited liability partnership of any or all of four different businesses in breach of Global Practising Regulation 3(2)(a): i) Accountability FD Limited ii) Bone and Co LLP iii) Finance Director Assist Limited iv) Accountability FD Limited 8. Allegation 2(b) referred to Mr Delo holding rights which in effect put him in the position of a principal in any or all of the four businesses listed above in breach of Global Practising Regulation 3(2)(b). 9. Allegation 1(a) and 2(a) pleaded the same breaches of the Global Practising Regulations but also alleged misconduct as alternative allegations to allegations 1(b) and 2(b). 10. Mr Delo has been an ACCA member since He is not a current holder of an ACCA practising certificate (PC) and has not previously held a practising certificate. 11. Mr Delo had previously applied for a PC. He submitted his first application on 25 January 2010 but the application form was incorrect. He was informed of this on the 27 January By 11 May 2011, ACCA had received three complaints regarding Mr Delo. 13. On 14 June 2011, Mr Delo had submitted a further incomplete practising certificate application to ACCA. Only recently has Mr Delo re-submitted his application for a practising certificate. 14. Mr Delo had advised that his Practising Certificate Training Record (PCTR) would follow shortly after the submission of his application. The current 2

3 application still requires a signature in relation to the PCTR. Without this document, ACCA is unable to process Mr Delo s practising certificate application. Mr Delo s recent application has been checked and apart from the resolution of a few minor matters once it is sent to Mr Delo s principal, Mr A, in Australia, it can be processed. (i) Accountability FD Limited (between 23 December January 2011) 15. Accountability FD Limited was incorporated on 23 December 2008 under the name D & F Accountability Limited. Companies House records confirm that Mr Delo was appointed as director along with Ms A. On 22 January 2009 the company name was certified as changed to Accountability FD Limited. 16. The Annual Returns dated 23 December 2009 and 23 December 2010 confirm that Mr Delo remained a director throughout this period. Mr Delo resigned his directorship on 31 January A letter was provided by Complainant 1 dated 15 June 2010 in which Mr Delo described himself as a director and the designatory letters, FCCA, appeared after his name. The contents of the letter showed that the firm was undertaking public practice work. 18. Mr Delo invoiced Complainant 1 for work done for the preparation of accounts and self-assessment tax return for year ending March 2010 and his LinkedIn profile on the 18 January 2011 stated that he held the position of director of the business and listed FCCA under the Honours and Awards section. The website of the business also described Mr Delo as a Fellow of the Institute of Chartered Certified Accountants in November On 26 November 2010, Mr Delo acknowledged that he did not have a practising certificate despite being a director of Accountability FD Ltd. He explained that he had had personal problems which had prevented him from completing the application process. 3

4 20. Correspondence continued between ACCA and Mr Delo. Mr Delo confirmed in an dated 10 December 2010 that he should have removed himself as a director until he had a practising certificate and that he had not signed or prepared any final accounts. He said he had removed any reference to his director status in his communications. He apologised and explained that his son had been critically unwell in hospital. 21. On 10 February 2011, ACCA set out the allegations against Mr Delo and the steps he was required to take in order to regularise his position and that this should be done by the 25 March On 4 March 2011 Mr Delo stated he was no longer a partner with Ms A. In a letter dated 18 April 2011, Mr Delo confirmed that he had set up Accountancy FD Ltd in January 2009 and he had remained as a director of the firm. The firm he said had 50 clients. 23. In his letter dated 18 April 2011, Mr Delo confirmed that all statutory work was conducted by his business partner, Ms A. He further confirmed that Ms A reviewed all management accounts. Mr Delo admitted that he had held himself out as available to undertake public practice work. 24. Mr Delo had provided confirmation of his professional indemnity insurance and that he had undertaken his continuing professional development. 25. In June 2011, Mr Delo submitted a further practising certificate application form. Mr Delo also advised ACCA that his former business partner Ms A had not yet signed forms allowing him to resign as a director of Accountability FD Ltd. Mr Delo again advised that he was not signing accounts and that if any clients needed tax work then he referred it to another accountant, Mr C. 26. ACCA spoke to Mr C who confirmed that there was an informal arrangement with Mr Delo on behalf of Mr Delo s clients. 27. ACCA submitted that Mr Delo s conduct brought himself, ACCA and the profession into disrepute and his eventual resignation came about as a result of the dissolution of the partnership with Ms A and not because he 4

5 was in breach of ACCA regulations. ACCA submitted the conduct showed a disregard for ACCA regulations. More importantly, ACCA submitted it brought disrepute to Mr Delo, his firm and ACCA as the public had been put at risk by Mr Delo being in charge of running a firm which carries out work that he has not been authorised to perform. Accordingly, ACCA submitted Mr Delo was guilty of misconduct. 28. The Annual Returns dated 23 December 2009 and 23 December 2010 confirmed that the business had a share capital of two shares. The Returns confirmed one of the two shares was held by Mr Delo. 29. The Annual Return dated 23 December 2011 stated that Mr Delo s share was transferred on 31 January In his letter dated 18 April 2011, Mr Delo admitted that he was a 50% shareholder. 30. Whilst the date in the Annual Return states that Mr Delo ceased to be a shareholder on 31 January 2011, he did in fact remain a shareholder until June 2011 as the paperwork took some months to resolve. He confirmed in his dated 29 June 2011 that the Companies House paperwork had been completed yet it awaited Ms A s signature. Mr Delo therefore appeared to the public and to ACCA to remain as a shareholder for a period of 6 months following the transfer of his shares. 31. ACCA submitted that that by virtue of Mr Delo s shareholding he held ownership rights in the company which allowed him to control the company in breach of Global Practising Regulation 3(2)(b). 32. ACCA further submitted that conduct brought Mr Delo, ACCA and the profession into disrepute as the conduct showed a disregard for ACCA regulations. ACCA stated his conduct brought disrepute to Mr Delo, his firm and ACCA as the public had been put at risk by Mr Delo being in charge of running a firm which carried out work that he had not been authorised to perform. 5

6 (ii) Bone & Co LLP (between 23 September January 2011) 33. Companies House records list Mr Delo as a designated member of Bone & Co LLP from 23 September 2009 to 31 January The application for incorporation is dated 4 September 2009 and is signed by Mr Delo. The application confirms that Mr Delo consents to being a member and a designated member of the LLP. Mr Delo confirmed in his letter dated 18 April 2011 that he was a 50% partner in the LLP. Mr Delo further confirmed that Ms A managed and controlled the LLP. Mr Delo advised ACCA that the LLP had approximately 250 clients. He further admitted preparing management accounts for one of the Bone and Co clients and attending their board meetings between November 2009 and January He said all statutory work was conducted by Ms A. 35. Mr Delo has provided confirmation of his professional indemnity insurance and that he has undertaken continuing professional development. 36. Mr Delo stated in a letter dated 13 June 2011 that he had taken all steps that he could to remove himself as a director but that his former business partner, Ms A was dragging matters out. 37. Mr Delo resigned as a designated member of the LLP on 31 January The resignation itself was not filed with Companies House until 23 September 2011 and Mr Delo appeared to the public to remain as a shareholder during the period January September In an dated 29 June 2011, Mr Delo confirmed that the Companies House paperwork had been completed yet it awaited Ms A s signature. 38. ACCA highlighted in its report that as the Companies Act does with respect to company directors, the LLP Act imposes a range of specific statutory responsibilities on members and, separately, designated members. In general terms, members are responsible for ensuring that the LLP complies with governance requirements, for example, to appoint auditors and to approve annual accounts, while designated members are responsible for preparing and submitting statutory information to nominated parties, in 6

7 particular the Registrar. Mr Delo was appointed as both a member and designated member and therefore his responsibility within the LLP was greater than that of an ordinary member. 39. ACCA submitted that Mr Delo knew or ought to have known that he was not able to hold the position of member of the LLP as he admitted that he was taking steps to obtain a practising certificate in 2008 when he became director and shareholder in Accountability FD Limited. Notwithstanding this acknowledgment, Mr Delo became a designated member of the LLP in September Mr Delo then submitted a defective practising certificate application in January 2010 and again in June ACCA further submitted that Mr Delo knew in 2008 and certainly by January 2010 that he required a practising certificate, yet he still had not taken steps to fully complete his application until very recently. It was submitted that his conduct brought Mr Delo, ACCA and the profession into disrepute as it showed a disregard for ACCA regulations. 41. Mr Delo was a designated member of the LLP as well as a member in the firm. Designated members perform statutory functions such as filing with Companies House. 42. All of the members of an LLP are entitled to share equally in the capital and profits of the LLP (pursuant to paragraph 7 LLP Regulations 2001). 43. By virtue of his position as member and designated member, Mr Delo held significant rights and responsibilities within the LLP. Given the responsibilities and rights held by Mr Delo and the fact that Mr Delo was one of only two members and could reasonably be considered as a principal of the LLP, ACCA submitted Mr Delo breached Global Practising Regulation 3 (2) (b). 44. Mr Delo continued to be a member of the LLP until his business partnership with Ms A broke down. Mr Delo knew in 2008 and certainly by January 2010 that he required a practising certificate. ACCA submitted that his conduct brought Mr Delo, ACCA and the profession into disrepute as it 7

8 showed a disregard for ACCA regulations. ACCA further submitted the conduct brings disrepute to Mr Delo, his firm and ACCA as the public was put at risk because Mr Delo was in charge of running a firm for a period in excess of two years that carried out work that he had not been authorised to perform. (iii) Finance Director Assist Limited (from 29 May 2009 to date) 45. Companies House records show that Finance Director Assist Ltd was incorporated with Mr Delo as a director on 27 May Mr Delo s occupation in respect of his directorship is listed as Accountant and the nature of the company s business is listed as Accounting and auditing activities. He was confirmed in the annual returns as director for 2010, 2011 and Mr Delo remains a director to date. He was told in ACCA s letter dated 10 February 2011 that he was in breach of ACCA s regulations by holding the position of director in Finance Director Assist Limited. 47. Mr Delo responded to ACCA by letter dated 18 April 2011 stating that the company was dormant and was not trading. He then filed dormant accounts with Companies House on or around 31 May ACCA submitted that whilst the name of the firm may not be considered as holding out as being available to undertake public practice work, the Companies House records, which are readily available to members of the public, state that the company is one which undertakes accounting and audit work. 49. ACCA highlighted in its report that Mr Delo took no steps to resign as director of Finance Director Assist Limited despite knowing that three separate complaints had been raised against him, that he was practising without the requisite authority of ACCA because he did not hold a practising certificate. It further submitted that Mr Delo must have been aware that he became the sole director of the firm following the termination of his business partnership with Ms A and her subsequent resignation as a director. 8

9 50. ACCA submitted that Mr Delo disregarded ACCA s regulations when he became a director of Finance Director Assist Limited and then ignored the notifications given to him that he was in breach of the regulations. Mr Delo s actions caused him to breach regulations and despite being aware of this, he has taken no steps to regularise his position. It therefore submitted that Mr Delo s conduct brought discredit to Mr Delo, ACCA and the accountancy profession and that as such he is guilty of misconduct. 51. At the time of the incorporation, Mr Delo held one of the two issued shares. He remained a 50% shareholder at the time of the Annual Return dated 27 May By the time the Annual Return dated 27 May 2011 was filed, he had become sole shareholder in the company and owned 100% of the issued share capital. Mr Delo retained his 100% shareholding at the time of the Annual Return dated 27 May ACCA submitted that Mr Delo took no steps to divest himself of his shareholding in Finance Director Assist Limited despite knowing that three separate complaints had been raised against him for practising without the requisite authority of ACCA in that he did not hold a practising certificate. Mr Delo failed to divest himself of his shares within the firm and took no steps to regularise his position for over 18 months. 53. By virtue of Mr Delo s shareholding he held sole ownership rights in the company which allowed him sole control over the company in breach of Global Practising Regulation 3(2)(b). 54. Mr Delo indicated that the company was dormant, yet the company was not dissolved. Although Mr Delo has applied for a practising certificate he knew he was under an obligation to regularise his position with ACCA in the interim to ensure that the public is protected. ACCA submitted that Mr Delo has failed to regularise his position with ACCA and remains the sole shareholder of Finance Director Assist Ltd despite the fact that the breach was brought to his attention as long ago as February In addition, Mr Delo has not yet submitted a signed PCTR. As a result, ACCA is unable to 9

10 process his practising certificate application and ACCA therefore submitted the public remain at risk. 55. ACCA further submitted that Mr Delo disregarded ACCA s regulations when he became a 50% and later 100% shareholder in Finance Director Assist Limited. Mr Delo s actions caused him to breach ACCA s regulations and despite being aware of that, he took no steps to regularise his position. ACCA submitted that this conduct brought discredit to Mr Delo, ACCA and the accountancy profession and as such Mr Delo is guilty of misconduct (iv) Accountability FD Limited, (formerly Accountability FD1 Limited) between 1 April 2011 to 12 August 2011 and again from 1 September 2011 to date) 56. Companies House records confirm that Mr Delo was appointed as the sole director on the date of incorporation of the new Accountability FD Ltd. 57. Mr Delo s occupation in respect of his directorship is listed as Accountant and the nature of the company s business is listed as Accounting and auditing activities. Mr Delo appears to have resigned as a director on 12 August Companies House records confirm that Mr Delo was reappointed as director on 1 September It is unclear why he resigned for a period of a couple of weeks. 58. ACCA highlighted in its report that Accountability FD1 Limited was incorporated on 1 April 2011, at which time Mr Delo was aware that three separate complaints had been raised against him for practising without the requisite authority of ACCA in that he did not hold a practising certificate. Mr Delo knew that his directorship with Accountability FD Limited and partnership in Bone & Co LLP had led him to be in breach of ACCA s regulations. Mr Delo acknowledged in December 2010 that he knew he had to resign his directorships. ACCA submitted that not only did Mr Delo fail to promptly resign his positions within Accountability FD Limited and Bone & Co LLP, he accepted the appointment of director of Accountability FD1 Limited in April 2011, some two months after being formally told by ACCA that he was not permitted to hold such positions. 10

11 59. ACCA submitted that Mr Delo was guilty of misconduct because he knew that his involvement in Accountability FD Limited was a breach of ACCA s regulations, and notwithstanding this; he became a director of Accountability FD1 Limited and changed the name so that it was in effect the same company. Mr Delo appeared to have incorporated this company despite ACCA s correspondence regarding his previous breaches. This company is now called Accountability FD Limited and Mr Delo remains a director. 60. ACCA submitted that Mr Delo s failure to adhere to ACCA s regulations is a serious matter, particularly as he would have been aware that his actions would breach ACCA s rules at the time when the company was formed. ACCA submitted that Mr Delo had demonstrated a lack of professional responsibility and a disregard for ACCA s regulations. It therefore submitted that Mr Delo s conduct in that regard amounted to misconduct. 61. The application to register a new company stated that Mr Delo was the holder of 100% of the issued share capital in the company. The Annual Return dated 1 April 2012 confirmed that the firm had a share capital totalling one share which is held by Mr Delo. 62. By virtue of Mr Delo s shareholding he held ownership rights in the company which allowed him to control the company in breach of Global Practising Regulation 3(2) (b). ACCA submitted this was a fourth company which Mr Delo had held an interest in, in effect acting as a principal without holding a practising certificate. Mr Delo s case 63. In a phonecall to ACCA on the 17 December 2014, Mr Delo admitted the facts of each allegation in respect of each company but he denied misconduct. He therefore admitted Allegation(1(b)(i), 1(b)(ii), 1(b)(iii), 1(b)(iv), 2(b)(i), 2(b)(ii), 2(b)(iii), 2(b)(iv). He denied Allegations 1(a)(i)-(iv) and Allegations 2(a)(i)-(iv) alleging misconduct. 64. Mr Delo stated that he was unable to obtain his practising certificate earlier because in 2010 his son became ill. Mr Delo stated that his son was ill to 11

12 the point where he required 24-hour care. He said that his son did not recover until September Mr Delo says that he had lost his sister-in-law to cancer and members of his family suffered with swine flu. His own health suffered during He had also recently split up from his wife for a period during In addition his financial security was severely affected due to the acrimonious business split with Ms A and his inability to work. 65. In a statement dated 17 December 2014, he stated he had a 50% stake in Accountability FD Ltd and Bone & Co LLP. He stated that Finance Director Assist Ltd and Accountability FD Ltd are dormant companies. 66. Mr Delo stated he and Ms A had engaged in a joint venture by way of accountancy businesses between December 2008 and He said by January 2011, Ms A had taken over 100% of companies (i)(ii) and (iv). He said his main role within the companies was to work on acquisition integration and producing internal management accounts. 67. He further stated that he had not intentionally or deliberately breached ACCA regulations. Admissions made at 7 January 2015 hearing 68. Prior to the start of the hearing Mr Delo heard the advice of the legal adviser as to the meaning of misconduct. 69. Having taken time to consider his position, at the start of the hearing Mr Delo admitted allegation 1(a)(i)-(iv) and allegation 2(a)(i)-(iv) in respect of each of the four companies. Accordingly the alternative lesser allegations of 1(b) and 2(b) were not put to him. DECISION ON FACTS/ALLEGATIONS AND REASONS 70. In accordance with Regulation 11(3)(c) of the 2014 Complaints and Disciplinary Regulations, amended on 1 January 2015, following the 12

13 admissions made by Mr Delo, the Chairman announced that allegation 1(a) (i)-(iv) and allegation 2(a)(i)-(iv) were found proved. 71. Since allegations 2(b) and 1(b) were lesser alternatives, the Committee were not required to make any determination in respect of those allegations. SUBMISSIONS ON SANCTION 72. Ms Cawley-Wilkinson submitted that Mr Delo s misconduct amounted to sustained breaches of the Global Practising Regulations and that during the relevant period Mr Delo had been aware of his obligations, having had the requisite knowledge since December Further, he repeated the conduct over a lengthy period of several years. Ms Cawley-Wilkinson submitted that his actions were aggravated by taking on further directorships and shareholding positions in the identified businesses (i)-(iv). She further added that had Mr Delo replied promptly to ACCA regarding his practising certificate he could have regularised his position long ago. 73. Ms Cawley-Wilkinson confirmed that there were no previous disciplinary findings recorded against him. 74. Mr Delo gave evidence in mitigation and was asked questions by the Committee. He stated the cumulative effect of family health problems, financial problems including almost having his home repossessed, redundancy in 2008 and a later acrimonious business split with Ms A had made obtaining a practising certificate less of a priority than it should have been. He stated that he was not someone who usually was remiss on such matters. In addition he had had to contest two applications for bankruptcy made by Ms A and assist a former colleague in relation to an unfair dismissal claim. He stated that he had wrongly failed to prioritise his application for a practising certificate because he was not actually practising and simply had an intention to practise. He accepted that he fell within the definition of public practice in respect of the businesses (i)-(iv) but that he was not actively involved in public practice. He stated that he continued to have to deal with the liquidation of company (i), and he had himself suffered from health problems due to the stress. 13

14 75. Mr Delo stated in answer to questions asked by the Committee that he would resign his directorships of companies (iii) and (iv). He also stated that there had been no trading between December 2008 and July 2009 of Company (i). He said he had been preoccupied with other business matters. He said he later became depressed and there was some inertia on his part due to his acrimonious business split with Ms A. He accepted that his son did not become ill until In summing up his case, Mr Delo stated that he did not believe the misconduct was serious but rather it was technical. He further added that circumstances had prevailed against him and he did not believe he had brought discredit upon anyone other than himself. In mitigation he said he was an honest and good, hard working man and he had not attempted to cover up his wrongdoing. He also relied on the fact that he been supporting his mother when she had suffered several strokes and when her brother passed away. 77. He apologised for his misconduct and stated he would resign all his directorships immediately. 78. Mr Delo further relied on letters submitted as references from a current employer and friend who knew Mr Delo between until Neither referee made reference to having knowledge about the current allegations. SANCTION AND REASONS 79. The Committee assessed the misconduct as very serious. Mr Delo had been without a practising certificate for several years when he should have held one and that his failure to obtain a practising certificate predated his family difficulties. It considered a member s failure to have a practising certificate when in public practice to be very serious because it put the public at risk. It accepted in mitigation that Mr Delo had applied for a practising certificate and that he had not practised mainstream accountancy and the businesses had been insured. However he had not obtained a practising certificate between December 2008 and 2010 when he should 14

15 have done and there was little explanation advanced by him as to why he had failed to do so. 80. The Committee concluded the misconduct admitted was not technical and in describing it as such Mr Delo showed he had limited insight into his failings. It was however persuaded that Mr Delo was now committed to doing all that was necessary in order to regularise his position including resigning his current directorships pending the processing of his application for a practising certificate. 81. The Committee accepted that the personal mitigation advanced by Mr Delo meant that cumulatively he had had a lot to contend with from It explained in part why he had acted as he had. The Committee accepted Mr Delo s mitigation that he had been preoccupied with other matters. However, it noted that there were several opportunities when Mr Delo could have regularised matters when invited to do so by ACCA but he had not done so. It noted that he had begun to apply for a practising certificate on two occasions and that he had not concealed his position from ACCA. 82. The Committee concluded that there had been little risk to the public from Mr Delo s misconduct and there was no evidence that the misconduct had resulted in any damage to the public or clients. It concluded that it was unlikely that Mr Delo would in the future pose such a risk particularly since he had stated he would resign all his directorships forthwith. 83. The Committee took into account that any sanction had to be proportionate. It decided that no further action and an admonishment were inappropriate and insufficient for very serious misconduct which was not isolated and which had continued for some time and where there was limited insight by Mr Delo into his failings. 84. The Committee then considered whether a reprimand was sufficient as a sanction, however it considered it was not because the misconduct was not minor and Mr Delo had not shown a willingness to regularise his position as soon as ACCA had drawn matters to his attention. It concluded that the misconduct was deliberate and intentional because Mr Delo chose not to 15

16 respond to the requests made by ACCA to regularise his position sooner and some years before. The Committee concluded that the risk posed by Mr Delo in the future alongside the corrective steps he had recently taken and his remorse and apology mitigated matters sufficiently that a severe reprimand was the appropriate and proportionate sanction and was sufficient to protect the public. 85. The Committee decided no other orders were necessary or appropriate. COSTS AND REASONS 86. The Committee accepted the evidence put forward by Mr Delo that he was as a result of his personal circumstances in financial difficulties and that his means were considerably reduced in part due to his difficulties in finding consistent employment and due to his mortgage arrears. 87. The Committee also took into account that Mr Delo had admitted both allegations albeit late in the day. 88. The Committee decided to reduce the costs applied for by ACCA of 5720 to 1800 on the basis of Mr Delo s financial hardship. EFFECTIVE DATE OF ORDER 89. The Committee decided that the order would be effective at the end of the expiry of the appeal period referred to in the Regulations. PUBLICITY 90. ACCA s regulations require ACCA to publish the Committee s orders and findings and as soon as practicable. The Committee has a discretion in exceptional circumstances to direct that the relevant person is not named. 91. The Committee heard no submissions from Mr Delo regarding any exceptional circumstances as to why his name should not be published with the findings and orders of the Committee as soon as practicable. 16

17 92. The Committee therefore ordered that the findings and orders should be published as soon as practicable, on ACCA s website and in the member s local press, referring to Mr Delo by name. Mr Chris Chapman Chairman 7&8 January

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