Monthly Archives: February 2018

Assigning a Lease and the Pitfalls, Authorised Guarantee Agreement (AGA)

Bad Beer For Export

Assigning a Commercial Lease and the Pitfalls, Part 1

Authorised Guarantee Agreement (AGA)

Introduction:- Most people, when they decide to take the plunge and become Self Employed in a Retail Business, end up taking a Commercial Lease, unless they have enough money to buy a Freehold.

By Retail, this includes licensed, catering, accommodation, dry goods, clothing etc., it also includes manufacturing.

A solicitor will brief you on the basics of your responsibilities on taking a commercial lease and very few stress the onerous responsibilities when you assign it.

They give you a copy of the lease to read and digest, at that stage you are nearly committed to take on your new career or project and assume that thousands of small business people have taken this step before you and survived.

A lot does depend on the Landlord, private landlords are often a lot easier to negotiate with, large companies can make things very difficult and costly.

Firstly always have a survey with photographs and agree this in writing with the landlord or his representative.

I made this mistake when I took a lease from a private landlord on a lock-up sandwich bar, there was nothing to it apart from a basement that had not been used for forty years, the freehold was sold to a large property company, who threw the book at me when I went to assign the lease with historic dilapidations in the basement, I couldn’t prove a thing because I did not have a survey.

Secondly always ask your solicitor about anything that you don’t understand in the lease, don’t let him tell you that it’s a standard commercial lease, it mat well be, but you still need to understand your commitment when you assign the lease.

AGA’s:-Privity of Contract is a very nasty clause, fortunately it was banned some years ago in new Commercial Leases and replaced by the Authorised Guarantee Agreement (AGA), it may still exist in some old leases.

Privity of Contract makes the assigning lessee responsible for all the new lessees until the conclusion of the lease in simple terms.

The AGA (Authorised Guarantee Agreement) makes the assigning lessee responsible for the duration of the new lessee and is released only when the lease is assigned to another lessee.

I had the local Licensing Officer ask me whether I could stop a Pub Company from taking an elderly couples bungalow after assigning their Pub Co lease about eight years before, because the lessees had gone bankrupt, we did manage to stop the Pub Co.

At the time the Pub Co’s were increasing rents to unrealistic levels and lessees were and are struggling, the new legislation is now having some effect on rental levels, but a vast amount of damage was done to good licensees, who have now left the industry and many that are left are struggling to make profits that vaguely equate to the enormous amount of hours that they work.

The landlord insists on references etc. on any new lessee, yet avoid any financial responsibility, because they can legally recover any of their losses from the assigning lessee, unless the lease has expired.

If you are a partnership or sole trader you can and will be hounded by certain companies for any shortfall caused by your assignee, so it is essential that you are happy with the financial state of your assignee and their ability, not that it is guarantee of their business ability.

If you have a Limited Company for the purpose of leasing a commercial property and assign, then close down the company the landlord can do nothing to recover any shortfall by the assignee, unless they have one or all of the Directors of the Ltd. Company underwriting any shortfall, which is to be avoided.

Certain lessees with hard nosed landlords, have assigned the lease then quit the country, certain property owning companies have long memories unfortunately.

In this computer and Internet Age people can be very traceable.

I personally think the AGA should be dropped from all commercial leases, those with Limited Companies can walk away, partnerships and sole traders cannot with the law as it stands at present.

Some Pub Co’s will allow you to buy out of the AGA, it has now become a revenue source and the price can vary from one company to another.

Looking at the AGA logically, if a lessee can buy themselves out of it, the AGA has minimal practical value to the Landlord except to extract additional cash from the hapless lessee.

The AGA in my opinion should be removed from all commercial leases where domestic accommodation is involved and families live on the premises.

Click on this link for legal information on AGA’s

ALMR echoes Committee’s call for Brexit clarity, possible Welsh Tourism Tax

Committee’s call for Brexit clarity, possible Welsh Tourism Tax

The ALMR has echoed the sentiments of the Home Affairs Committee’s report on delivery of Brexit and called on the Government to provide more clarity on ongoing and future processes.

The Committee has called for detail on a range of issues including the legal status of EU and EEA citizens in different circumstances. These range from issues pertaining to the length of individuals’ current residence in the UK, to the timing of their registration to remain in the UK, family reunion rights and addressing periods spent outside of the UK.

ALMR Chief Executive Kate Nicholls said: “The Committee’s report rightly raises a number of questions that must be addressed by the Government. At present, there is still too large a grey area regarding the rights and status of non-UK EU nationals and the detail of the post-Brexit immigration system.

“The Government has made some steps to provide reassurance, but employers and employees still need a great deal more clarity. The Committee has called on the Government to provide more detail and it is vital that we get a positive response, so as to allow businesses and their team members time to plan ahead.”

 

Kate Nicholls, CEO of the ALMR, the leading voice for the UK’s eating and drinking out sector, comments:

“This is a welcome decision and credit must go to Hospitality Cymru for leading efforts to secure it; although the Welsh Government would show more pragmatism if it abandoned the idea completely.  A Tourism Tax would only heap costs on businesses and customers and make tourism in Wales much less attractive and competitive. The ALMR will continue to oppose the tourist tax and I hope that Governments all around the UK will act positively to avoid the introduction of such a flawed and unserviceable measure.”

ALMR

 

JG&Partners, The Licensing Officer Scam!

 

The Licensing Officer Scam!

Posted: 13 Feb 2018 09:00 AM PST

Swale Council have recently written to their licensees to warn against a confidence trickster operating in their area. The scam involves a criminal attending the premises and posing as a Licensing Officer, demanding payment of the licence annual fee in cash. As with many successful scams the proposition is plausible and the person making the demands appears to know a number of relevant facts …

Pub Co’s, “Have they hit the Wall of Reality”, Barrel-Dregs.

Bad Beer For Export

Pub Co’s, “Have they hit the Wall of Reality”, Barrel-Dregs.

My sources in the Pub Co world tell me that certain Pub Co’s may well have “Hit the Wall of Reality” and things are not happy in the individual Camps, are well it had to happen at some stage, you can’t keep milking a cow after the udders are dry, my farmer friend has always reminded me.

Their policy, has in the main been that Licensees were a an expendable commodity,  they had peddled from Day One that buying a lease was the way to earn Serious Money and incredible Capital Gains, when they eventually sold the lease, a few did in the early days, statistically the majority didn’t.

Leases in the main are now a millstone round most licensees necks, the rents were and are outrageous, the terms of the leases draconian.

The BDM’s in many cases had no experience of running pubs profitably, many were ex sales people, well experienced in debt collecting, this suited the Pub Co model, as long as licensees were expendable.

The Senior Pub Co Management were and are Money Men, not like the genuine brewers who knew exactly how much beer they could expect to sell in their catchment area.

Tied Pub Leases, were almost unheard of until the Pub Co’s came on the scene, you had freehouses, brewery tenancies and untied pub leases.

Discounts were minimal, credit was one calendar month, with freehouses it was a great career with substantial capital growth, if you were a good operator you could float a reasonable amount of working capital by using your credit terms sensibly, not so with Pub Co leases, two weeks credit, after that the Pub Co debt collector is on your doorstep.

The good old Family brewers treated good licensees as their key to a successful company, they were brewers of beer, and the more successful a Licensee became the more profit they all made.

The brewers system was a short term Tenancy at sensible rents, that gave reasonable operators a profitable career for life, sadly many of the family brewers have jumped on the Pub Co Bandwagon or been bought out by the money men, the breweries have been demolished and converted into expensive housing.

A number of family brewers still operate and some still observe the principle that good  licensees are the key to good business.

Back to “The Wall”, it would appear the amount of people having been made redundant clutching their redundancy money in their hands, has dropped dramatically.

Redundant people were a very soft target for Pub Co’s, a career change taking on your local pub, not anymore, the others were South Africans getting away from the many problems in South Africa.

It would appear that the rush of potential licensees with cash has diminished, too many good operators have left the industry, never to return, the Pub Co’s can only blame themselves, what was a safe career is now a highly precarious one with a Pub Co Lease or even a tenancy is highly questionable.

We have had too many good operators pouring their hearts out in despair at Pub Co policy and questionable tactics.

The draconian leases and lousy trading conditions, you can’t just give up and assign a lease, you’re responsible for the incoming lessee financially, added to the dilapidations, in many cases think of a number double it and clobber the outgoing lessee for whatever little he has left, in some cases the work was not carried out and passed on to the unknowing new lessee, this is illegal and worth pursuing with a good surveyor.

I had been called in to a distraught lessee, where the BDM told the lessee that the company carried out a survey at every change when he took on the lease,  he saw no need to get an independent survey, the historic dilapidations were a nightmare which the Pub Co tried to claim for, the BDM had been moved to another area and denied all his previous statements.

It would appear not only are potential licensees avoiding Pub Co Leases, but the BDM’s are leaving for a quieter life, not that many of them were a help to the struggling lessees.

It also appears from a stressed Area Manager that one Pub Co has the highest number of managerial staff off on sick leave, maybe they should merge with the NHS.

The current Flu epidemic, may be used as the excuse, but my sources tell me that stress and dissatisfaction with lower managements limited responsibility to make a decision, whilst senior management have little or no idea and over rule most decisions made, sounds like the First World War, where the troops at the front were Cannon Fodder and the Generals sat at the back totally unscathed.

This leaves the remaining managers running round vast unmanageable areas like “Headless Chickens”, however much they try.

They cannot make a decision of any degree of importance without the Blessing from the Almighty, who may also be on Sick Leave according to Potboy, who is normally spot on with his info.

If this info is correct and I have no reason to doubt it, BDM’s and Lessees will be in greater demand and without them the tree will start to shake.

Some Pub Co’s are making realistic deals at long last, subject to confidentiality agreements, in case other lessees catch on.

One Pub Co that I have crossed swords with on a number of occasions, substantially reduced the rent on a pub going through an appeal and then offered to give £150 per barrel discount across the board to keep the lessee, I don’t like the Pub Co, but if they act that way they will get my full backing, it’s a serious step in the right direction if correct, and I am assured it is.

The overall business is shrinking from the Trade Press, it’s time to change, sadly it won’t, the Pub Co attitude has gone too far off line for senior management to change, many have taken vast sums out of the industry, which has become endemic, but without good front line management and good licensees the whole system could start crumbling.

There is more next week, but it appears “The Wall” could be in danger of tumbling, unless a different approach is taken very quickly.

The attempts by most Pub Co’s to circumvent the Government Legislation may come home to roost with a vengeance, if they have no front line managers and even less licensees.

Barfly

Historical Note:-

Lease with a Sting in the Tail LINK

The Great Pub Co Con LINK

BD Less savoury.eps

The views expressed are not necessarily the editors and www.buyingapub.com accepts no responsibility for them, we do try to avoid offensive or litigious statements being made. They are written by concerned professionals in the industry who feel that these issues should be raised to ensure that all licensees are made fully aware of many hidden pitfalls. 

copyright (©) 2018, www.buyingapub.com

ALMR reacts to Government employment plan

ALMR

ALMR reacts to Government employment plan 

The ALMR has responded to publication of the Government’s Good Work plan and welcomed steps to address illegal use of unpaid interns but called on the Government to provide additional clarity for businesses.

ALMR Chief Executive Kate Nicholls said: “This is a welcome, proactive approach from the Government in an area that many employers and employees feel passionately about. We do not want to see abuse of internships, and action to ensure that employees are paid should help increase transparency and confidence across businesses. We do, however, need to see more guidance on issues like work experience where young people, particularly those still at school, are being offered short-term placements in businesses as these can provide a valuable first taste of work.

“We want to make sure that these opportunities are still available and that businesses are fully aware of their responsibilities. We will be working with the Minister to ensure that information is readily available and communicated to the sector.”

The ALMR has also responded to the Government’s measures to address perceived deficiencies in flexible working practices.

Kate Nicholls added: “This approach from the Government will bring some peace of mind to workers looking for reassurances and will ensure that businesses that need to employ people flexibly will still have the opportunity to do so. Hospitality businesses often rely on flexible working to suit seasonal demands and in our discussions with members we have found that this suits both employers and employees.

“The Government has, however, missed an opportunity to overhaul NICs for younger workers that would benefited both workers and businesses looking to invest in staff. Scrapping NICs for under-25s would have put more money into pockets of staff members and freed-up money for businesses to invest in their teams.

“Any changes to the rate of National Living Wage or Minimum Wage for flexible workers should come as a result of appropriate consultation and assessment by the Low Pay Commission and should reflect economic circumstances and be affordable for businesses.”

JG&P, Monthly Licensing Update

John Gaunt and Partners

Welcome to our Licensing Update

Please note some of these issues have been posted during the last month

 

A Right Royal Knees Up? Home Office Launch Royal Wedding Consultation 

A four week consultation was launched by the Home Office on plans to allow Licensed Premises to open on the nights of Friday the 18th May and Saturday the 19th May until 1am. The consultation is now closed and it is widely expected that the proposed extensions will be granted.Read more here

PASS Card Update

On the 17th January PASS (Proof of Age Standard Scheme) launched an updated card format which includes the National Police Chief’s Council (NPCC) logo plus the logo of the Security Industry Authority (SIA).Read more here

Merger to Create “Powerful Unified Voice” for the hospitality sector “UKHospitality” 

The Association of Licensed Multiple Retailers (ALMR) and British Hospitality Association (BHA) have revealed their plans to merge and create a new trade body named “UKHospitality”.  The proposed merger is to be voted upon at an EGM of the ALMR on the 21 February 2018.Read more here

Alcohol Minimum Unit Pricing – Select Committee scrutiny 

The Committee heard evidence focused on the potential impact an Alcohol Minimum Unit Pricing (MUP) could have on health, healthcare, the criminal justice system
and any cross border implications posed by decisions of the UK, Scottish and Welsh governments.

A report of the Evidence heard by the committee can be found here. We will await any further analysis or recommendations from them as a result.

MP’s back Agent of Change Bill 

At its first reading on the 10th January 2018, the House of Commons gave approval to the Planning ( Agent of Change) Bill.  The proposed legislation would require property developers to take into account pre-existing businesses, like music venues, before proceeding with a project.Read more here

Consultation On The Future Of London At Night 

The London Night Time Commission consultation has had its deadline for submissions extended until 10 a.m. on Tuesday 20th February.  Meanwhile it has been reported that Philip Kolvin QC has resigned as chair of Chair of the Night Time Commission.Read more here

Food Hygiene Prosecution 

A Birmingham restaurant learned an expensive lesson in relation to food hygiene when it was fined £50,000 by Birmingham Magistrates’ Court.  They had adopted the use of wooden boards as is currently popular in substitution for plates. However, due to repeated use those boards had fallen into a condition whereby they could not be effectively cleaned and indeed the Inspectors stated in evidence that they were incapable of being cleaned.Read more here

The 15th National Pubwatch Conference – Tuesday 27th February 2018 

The 15th National Pubwatch Conference will be held at the Crowne Plaza Hotel, Nottingham on Tuesday 27th February

Read more here

Liverpool Council first to debate benefits of Minimum Unit Pricing of Alcohol? 

A special health summit looking at the effects of Alcohol took place in Liverpool last week.  Liverpool Council were to meet with Public Health officials, the NHS and Alcohol Charities to discuss a plan for Alcohol in the City. One of the main discussion points is minimum unit pricing:Read more here

Short changed on a coffee? 

In case of passing interest…  It is being reported from the USA that a class-action lawsuit accusing Starbucks of under filling lattes has been thrown out by a judge in Oakland, California.  The US district judge found insufficient evidence that Starbucks “cheated” customers by under filling lattes by making its cups too small, using “fill-to” lines on baristas’ pitchers that are too low, and instructing baristas to skimp on ingredients, such as by leaving a quarter-inch of space on top of the drinks.  The judge also said foam counted as part of the drink’s volume (similar in part to the froth on a pint of beer here, as long as within limits).Read more here

Gambling – Betting shops: licensing and planning issues – a briefing document

This House of Commons Library briefing paper looks at licensing and planning issues relating to betting shops in Great Britain.  There are some 8,500 betting shops in Great Britain (Gambling Commission statistics, November 2017).  The briefing document can be found here: ‘Betting shops: licensing and planning issues’

Gambling – Commission launches new consultation on LCCPs 

The Gambling Commission have today launched a new Consultation regarding the LCCPs.  The proposed changes can be found here (which are tracked in the consultation document).  The stated aim of the changes is to make clearer requirements that operators are fair and open with consumers.

The Commission’s proposals are stated to be founded upon evidence of potential harm or unfair treatment of consumers, concerns about lack of compliance with consumer protection legislation, declining public trust in gambling, and concerns about the impact of gambling on children and young or vulnerable people.Read more here

And finally…

Upcoming opportunities

In a new feature, we look ahead to the next few months to highlight some one-off events that may be beneficial to your operation:

  • Winter Olympics – between 9 and 25 February in Pyeongchang, South Korea (GMT +9) followed by the Winter Paralympics from 9 to 18 March.
  • Easter Weekend – Friday 30 March to Monday 2 April.
  • Anthony Joshua’s unification fight against Joseph Parker has now been set for 31 March in Cardiff.
  • Royal Wedding on the 19 May (see above)

On trade beer sales drop underlines need for business rates reform

ALMR 

On trade beer sales drop underlines need for business rates reform

Commenting on the publication of beer sales figures today, ALMR CEO Kate Nicholls said: “The beer sales upturn reflects Government having listened to the united industry that lobbied on beer duty. However, the continued downturn of beer sale in pubs only emphasises the urgent need for Government action to address the other prong of our campaigning – business rates.

“The inequitable skew of the current business rates system favours digital enterprises and punishes pubs. It’s just not compatible with successful high streets and pubs.

“Pubs are facing ever-increasing costs and something has to give. The Government’s manifesto committed to reforming business rates and today’s figures are just the latest proof that swift action is critical.”

Pub Co, Licensees Horror Stories 4 (Barrel Dregs)

 

Barrel-dregs 3

Pub Co, Licensees Horror Stories 4 (Barrel Dregs)

Another sorry story

Barfly,


Thanks for your help, I got stuck behind the bar again last night. I did however fish the leaflet out and I am calling them today. It’s all gone horribly wrong here (after a year of profitable trading).

My dad who I need for some kind of help in forming an action plan has stuck his head in the sand but the pub is losing about 2k a week and I am going crazy with worry.

The loan for the assigned lease is secured against my parent’s house (120k) and the guilt I feel for bringing the family to this, is immense.

We are on the Pub Co’s recovery scheme with 100 off 36gall but is drop in the ocean compared to the bills that are racking up…..Weekends are still busy but whereas we were taking 1 to 2 k on weekdays we are now doing 500 quid if we are lucky. It all started in October and really suddenly! I blame myself for not reacting but what could I have done in such a huge downturn. I’m at a loss as to what to do now as my dad who has been in business (not pubs) all his life just says hang in here, but I know it’s too late already. 

The Pub Co can’t do anything as I’m on the discount already, bailiffs have walking possession of fixtures & fittings due to rates arrears and I’ve not paid food suppliers for 3 months. I just want to walk but my dad just won’t surrender the 120k investment and I don’t blame him!

If it wasn’t for the greed of the Pub Co and we were paying a sensible tied price for our beer we certainly wouldn’t be in this mess!

Sorry to put this on you as you don’t even know me but I needed to get it off me chest. I will be at the meeting on Monday. I really don’t know why the whole tied system does not wake up and revolt by just not buying from the Pub Co’s.

I feel it’s the only way.

BD Less savoury.eps

Supporting Charities

 

Supporting Charities?

I had always supported the big national charities, until I bought a pub, they always appeared to be doing an incredibly worthwhile job, some do, but how do you tell the difference?

Since buying a pub, many have come under scrutiny for a variety of reasons, the directors salaries, how much money goes to good causes, political persuasions, the amount of money spent on advertising, legal disputes over money left to them, the list is substantial and a minefield.

I’m not saying do not support them, but check them out, I now have a very simple rule, I only support local charities, like Hospice and Children’s Hospice, the work that they do is amazing and is funded in the main by donations.

A very close relation went into the local Hospice, what they did for her was incredible, I then looked at Children’s Hospice and changed my whole view on supporting charities.

I initially spent money on advertising, which is like pouring money down a bottomless pit, with minimal result, I thought it would be better to give the money to charity.

I was then approached by both Hospices, to see if they could leave a collecting box in the bar, which I agreed, then a thought crossed my mind, why not have a free food night in aid of Hospice, all donations will be collected in a bucket, all drinks will be paid for.

The result was amazing, we had a lot of fun, raised a lot of money, the long term result was staggering, people loved our food and came back and turned our local business around.

I stopped wasting money on advertising, customers were delighted that we supported local charities and we all felt that we had done something worthwhile for a good cause.

Now, I advise people, if their operation is food based, once you have your food quality right, to have a free food night in aid of your favourite local charity, the charity will always advertise the event, their advertising and mailing list is far more effective than whatever you have access to.

I would suggest one, a few months after you have taken over a new business and then twice a year, do not put out inferior food, it is a showcase for the quality of your food, the better it is, the more money you raise for charity.

There are research charities, who do amazing jobs and need the money, but sadly most are hardly known by the public and the local response can be limited, you want to raise money for charity and cut out advertising money, local charities need it more than big charities.

We did it regularly, bringing in many people that would not normally eat in a pub, who became regular customers and part of our core business.

We also raised a lot of money for the two local key Charities, we also stopped wasting money on advertising.

We and the staff thoroughly enjoyed the evenings.

Barfly

 

 

 

 

Pub Co, Licensees Horror Stories 1 (Barrel Dregs

Barrel-dregs 2

Pub Co, Licensees Horror Stories 1 (Barrel Dregs)

A sorry story

I just hope that if any Pub Co Boss or Employee reads these terrible stories, they feel some degree of remorse. I just wish that they were not true, but they are and they won’t stop coming in. 

I am currently struggling with a Pub Co. The latest letters from them threaten to take back our three pubs we face mounting costs and accusations of buying out. My situation is being re-played the land over, I am paying £100 a week rent and they want £1000. I refuse on the basis that the business is non-viable, no discounts (aside from one old lease at £40 a brewer’s barrel). I am paying this rental amount as I cannot afford their full rent. What I  want is to pay a fair rent and to be given discounts as a part of our Partnership agreement.

We have asked for help over the last 18 months. We are still awaiting capex and safety works to be done at two of the premises, the original works are now over two years old and have lease works which are even older. We received a BRI (Business Recovery Incentive) at one pub.  This was changed into a deed of variation, based on the fact that the rent had been set to high since the refit. We asked for the rent to be back dated to day-one and were told that this could not be done as they had overspent on the capex (although the rent was set at the end of these works).

Any BRI deals offered did have tie-ins contrary to the Pub Co’s statement to the BEC, namely WSM (wines, spirits and minerals) and or f&f (fixtures and fittings.) They allowed a short term discount of £100 a BB (Brewer’s Barrel) to carry on which they then called in. Due to an oversight on their part we were hit with a bill of £12k which we cannot afford.

We have asked for full breakdowns on how the rent is assessed so that we can challenge it. This information has not been made available although we have asked for it repeatedly over the last year or more. 

I do have a rental breakdown (given over to confuse us rather than help, but which has proved very helpful.) This was provided by my Regional Manager, for another lease, which we challenged only to have their chief surveyor turn up and give a new, completely different, assessment but still arrive at the same rental figure! We challenged his figures and were not allowed to speak to him again. Then the Director came down to tell us to pay or go to arbitration. After we displayed some of the errors carried out by their surveyor the Director left with the promise to look into it. He came back with a lower rental figure, which was still way off the mark, and refused to show us any calculations. We were told arbitration was the only route. He completely missed out the fact that an external valuer should have been called in, as per their Codes of Practice.

Their area manager approached us before Christmas to say that he could offer us temporary discounts at £50 per BB at all sites and he would put the rents to zero so long as we agreed to be out by the 2nd week in January (he tried to tie us in for WSM as well but we referred him to the Pub Co’s comments at the BEC and he withdrew this part). We said we would be happy to take up his offer on the discounts, as we had been asking for this level of help for a year, but not on the basis of surrender as we wanted to discuss our situation with their CEO. The deals were put in place and then revoked at the end of a short period, with us having to pay back the discounts before orders would be accepted. Rents for January (previously removed) were added back onto our debt.  They are not willing to freeze rents during negotiations even though they have already proved they can.

We then took our complaints to the CEO, he said if you pay your bills then I will talk to you. He is fully informed of the practices used by his company and directly liable as he cannot deny being told. We could not pay these debts, we gave an explanation as to why this was so and what we were doing to further the business. We have now received mail saying that he will not talk to us any further and the case(s) will be handled by their solicitors.

We have been on cash with order for over a year now and yet weekly our beer deliveries are being  delayed due to problems within credit control and no fault of our own. This kind of petty harassment is hugely damaging to a business.

There are so many elements to this case that I could write forever. I have been given no choice but to publish this information to try and help others.  I am seeking legal advice on the best way forward. Needless to say the evidence has been submitted to the Inquiry. The information on your site is accurate, and I thank you for posting it, but I don’t know the best way to get the PubCo’s to implement change.

I talked to both Fairpint and David Morgan who have offered advice. I will carry on the fight but I wanted you to know that having sites like yours allows people to read about the truth.

BD Less savoury.eps