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I S S U E 1
Featuring Cherie Blair
L A R K I N S U R A N C E . C O . U K
2
@larkinsurance Lark (Group) Limited
3
Welcome to Larklink, our new publication to connect with clients and highlight the latest insurance issues and legal changes that are likely to affect your company.
In an exclusive interview with Cherie Blair QC, the human rights' lawyer talks about the continuing battle for women's equality. From the gender pay gap to quotas on company boards, Cherie voices her impatience with the low number of women in government and the ramifications this has on society.
Mind the Gap is the theme of our first Larklink which aims to ensure you don't trip.
Every organisation has unique challenges when it comes to protecting the business and an increasing threat comes from cyber crime. Newly revealed figures show the UK is the second most vulnerable when it comes to cyber attacks and we offer advice on insuring against the consequences.
We also explain The Insurance Act in simple terms, identifying the legal implications and challenges your business might face as the first major change to commercial insurance in a century kicks in.
Underinsurance is also on our radar as we look to bridge the gap with expert support.
Landlords failing to meet energy efficiency ratings could risk fines of up to £5,000 and can exceed this for non-domestic properties. Don’t get caught out.
With wellbeing and happiness at work being quoted as being as important as annual pay, many employers are reviewing employee benefit packages to help recruit and retain the best calibre of staff. We focus on critical illness cover which can ease worry during a Patient’s recovery.
We are here to provide the most appropriate solutions at the best terms - wrapping a security blanket around your business - so we hope Larklink
provides a platform for you to Mind the Gap.
Julie Whitehead
Director
4
5
Firstly, it’s a great pleasure to feature within our first Larklink publication for our corporate clients.
Since 1948, when my grandfather founded the business, we have always believed that the core culture should be built around strong client relationships and providing a tailored service.
Here we are some 67 years later and although a lot has changed over these years this ethos still remains at the heart of Lark and its employees.
Back in 1988, with my student days complete, I was keen to work in the financial sector and so some experience in what was then a family business, seemed like a good place to start. I initially gained experience through each part of the business, including spending time as a Lloyd’s broker, before becoming a Partner in 1993, after completing my insurance exams. I then took on the role of running new business for our Commercial and Private Client teams before becoming Group MD in 1999.
Back in 1988 things were very different as Lark only had one office location with 80 members of staff. Looking back now I think one of the areas that has given me the most satisfaction is how the business has grown in a controlled way and how many of our people have been able to develop their careers within the business. We currently have over 135 employees who have been with Lark for more than 10 years, this just illustrates the positive culture I think we have created…who says insurance can’t be fun!
The business sectors in Lark have also evolved since 1948; the core of the business back then was placing risks into the Lloyd’s market on behalf of UK regional brokers. This is something that has reduced in size and importance to us over the years and now forms just a small part of what Lark does today.
In the 70’s, 80’s and 90’s Lark enjoyed a long and successful relationship with Sedgwick, until their acquisition by Marsh in 1999. At this point Lark became 100% independent again and between 2002 and 2014 we made 12 acquisitions of UK regional broking businesses and rationalised these into the Lark you see today, 330 people across our seven locations handling Commercial, Private Client and Employee Benefits business.
Away from work, my three teenage daughters
keep my wife and I in check and I enjoy escaping to the golf course on a fairly regular basis. I am also a keen follower of other sports, including cricket. I try to contribute back to the insurance sector through an involvement with the Chartered Insurance Institute and also to the area where we live in Kent.
As far as the immediate future is concerned for Lark, our plan is to continue our steady growth, increase investment in our online presence in specific product lines, see marketing play a bigger role in driving our new business efforts, and continue to look out for appropriate acquisition opportunities of people and businesses who share the same values as us.
I hope you enjoy our first edition of Larklink, I’d love to hear your feedback so please do not hesitate to get in touch:
Enjoy the remainder of 2015.
I n t h e
BoardroomLark
S T E P H E N . L A R K @ L A R K I N S U R A N C E . C O . U K
Stephen
Roger Lark and Sons was established as a Lloyd's
Broker in 1948.
A BRIEF HISTORY OF L ARK (GROUP) L IMITED
— 1948, ROGER L ARK AND SONS WA S
ESTABLISHED A S A LLOYD’S BROKER
— 1960, THE Y MOVED TO
IBE X HOUSE, MINORIES
— 1968, THE COMPANY
EMBARKED ON A SUCCESSFUL
A SSOCIATION WITH SEDGWICK
— IN 1977, ROGER L ARK L IFE &
PENSIONS LTD WA S ESTABLISHED, L ATER
KNOWN A S L ARK EMPLOYEE BENEFITS
— 1990, THE COMPANY CHANGED ITS
NAME TO ROGER L ARK & SEDGWICK
— IN 1998, SEDGWICK ANNOUNCED ITS
PL ANS TO MERGE WITH MARSH, AND
SO IN 1999 THE COMPANY CHANGED
ITS NAME ONCE AGAIN - TO L ARK
INSUR ANCE BROKING GROUP – AND
BEC AME A L IMITED COMPANY
— 1999, ROGER L ARK’S GR ANDSONS,
GR AHAM AND STEPHEN, BECOME
CHAIRMAN AND MANAGING
DIREC TOR RESPEC TIVELY
— 20 02 - 2014, THE COMPANY MAKE
12 ACQUIS IT IONS OF UK REGIONAL
BROKERS AND CRE ATES THE 7
CURRENT OFFICE LOC ATIONS
— 2012 AF TER REBR ANDING L ARK
BECOMES L ARK (GROUP) L IMITED
6
Insurance ActK e y p o i n t s y o u N E E D t o K N O W a b o u t
t h e f i r s t s i g n i f i c a n t c h a n g e t o C o m m e r c i a lI n s u r a n c e L a w i n m o r e t h a n a C E N T U R Y
THE INSURANCE ACT 2015 WILL COME INTO EFFECT THROUGHOUT THE UK IN 2016.
Julie Whitehead, Director at Lark, outlines the changes and explains how organisations can prepare for it.
The Insurance Act 2015, which applies to all classes of non-consumer insurance and reinsurance, comes into effect on 12 August 2016. Bringing into force the Third Parties (Rights against Insurers) Act, with minor corrections, it represents a significant change to the legal framework of insurance contracts, which has been untouched since the Marine Insurance Act 1906.
THE KEY PROVISIONS OF THE ACT ARE AS FOLLOWS:
The Insured will be under a new duty of fair presentation, replacing the general obligation to disclose all material facts. The Insured will have to disclose every material circumstance that he or she knows or ought to know, or sufficient information to put a prudent Insurer on notice that it needs to make further enquiries to reveal the material circumstances. Currently Insurers are not obliged to make further enquiries and can rely totally on what is disclosed to them. This applies to disclosure before the contract is concluded, for new contracts and renewals, as well as mid-term variations.
Warranties are to be treated as suspensive conditions, meaning that an Insurer’s liability will only be suspended during a period of breach and a breach of warranty will no longer automatically terminate the policy. The breach of the warranty must have some bearing on the actual loss by increasing the risk of the loss occurring.
New proportionate remedies are available to Insurers following a breach of the new duty of fair presentation. For example, where a deliberate or reckless breach of fair
presentation occurs, Insurers can still avoid the insurance and retain any premiums paid. This would normally be from inception except where the breach relates to a variation such as a mid-term adjustment. The onus will be on the Insurer to show that a qualifying breach is deliberate or reckless.
Remedies are also available for other breaches of duty of fair presentation. These are based on what the Insurer would have done if the qualifying breach had not taken place and the Insured had made a fair presentation of the risk. For example, if the Insurer would have charged a higher premium, it can proportionally reduce any claim payment or it may impose additional terms retrospectively.
Basis of contract clauses are abolished. These clauses currently operate to turn the Insured’s pre-contractual representations, including answers to proposal form questions, into warranties.
Insurer remedies for fraudulent claims are clarified so they will remain liable for all legitimate losses suffered before the fraud.
The duty of good faith remains but the remedy of avoidance is only available if cover would not have been offered if a fair presentation had been made. With the exception of the basis of contract provisions, parties to an insurance agreement can contract out of the requirements of the Act, provided that any disadvantageous amendment is drawn to the Insured’s attention clearly and unambiguously. We are not expecting our key Insurers to be going down this route.
NEXT STEPS
Although the changes won’t come into effect for more than a year, it is important to start planning for them now. Organisations will need to ensure they are able to satisfy the new law and that they have adequate and effective internal corporate governance and communication protocols in place so that relevant employees are fully conversant with the changes. A good example of this is the
new duty of fair presentation.
Although the change may seem subtle, it will require the Insured to introduce new processes to ensure compliance. For instance, the Insured will need to make sure a reasonable search is undertaken to reveal material information and that it makes the disclosure in a manner that is reasonably clear and accessible to a prudent Insurer. In addition, although the information can be contained in more than one document or oral presentation, data-dumping a large volume of information with insufficient direction of structure would not be considered fair – key facts must not be buried within less relevant information.
Organisations are likely to see changes ahead of the introduction of the Act. We expect that Insurers will be more amenable to altering policies to follow the spirit of the Act, for example, removing basis of contract clauses and improving warranty language.
We will be looking to discuss with our key Insurers the possibility of implementing these changes before the Act comes into force. In summary the key provisions that this act addresses are basis of contract clauses, suspensive warranties and remedies for non-disclosure.
We will also, in consultation with Insurers, agree parameters for what is deemed to be a “fair presentation of the risk”. We will provide the appropriate guidance and support to all of our clients, to ensure that broking information is sufficient and compliant.
For more information about the Act, and
how to prepare for it, please call your Lark
Account Handler or alternatively contact
Julie Whitehead with any enquiries:
020 7543 2809
1 2 3 4The pre-contract duty of
disclosure has been replaced by
a new duty of fair presentation;
The law on breach of warrenty
has been changed;
the law on fraudulent claims is
clarified and remedies for such
claims have been set out in the
act; and
Provisions for contracting
out are included, subject to
compliance with transparency
requirements
KEY CHANGES
the
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Industry NewsIndustry News
8
Claims Corner
9
In this article, we seek to demystify two simple, yet fundamental claims related questions about what is a Claim and what
is a Circumstance.
WHAT IS A CLAIM?
These type of policies are written on a “claims made” basis, that is, unless otherwise provided, the policy only covers claims first made against an Insured during the policy period, regardless of when the occurrence took place, subject to this being within the retroactive date agreed within the Policy. Claims arising from events prior to the retroactive date are excluded.
A policy will generally define a claim as:
— A written demand
— A civil, regulatory or administrative proceeding, including mediation or arbitration
— A criminal proceeding which alleges a wrongful act by an Insured person
Many policies will also include a regulatory investigation, for example, HSE, FCA, SFO and OFT investigations.
The policy requires you to give notice in writing of any such claim. Generally, policies may also require you to notify a “circumstance”, which is something that is not yet a claim, but may in the future become a claim. Each policy will have a slightly different definition of what a “circumstance” is and when to notify it. The following may be helpful (see examples right).
EXAMPLES OF A “CIRCUMSTANCE”
— The removal or resignation of a Director or Officer if not completely voluntary
— An intimation that someone may make a claim against a Director, Officer or other Insured Person
— An awareness of a failing in your Company’s performance, or a real doubt of a Director or Officer’s ability to undertake their duties
— An allegation, even if you consider this to be completely unfounded, that any Insured person breached their fiduciary duties, whether express or implied
— A statement that someone intends to bring a suit or other proceedings
— An oral threat or allegation
It is important that immediate notification to your usual Lark contact or Insurer is given as soon as you receive any spoken or written claim, complaint, criticism, allegation of negligence, an indication of intent to make a claim against any Director, Officer or other Insured Person. Do not make any admissions or concessions, or agree to make any payment without the prior written consent of your Insurers. If you need to appoint a Solicitor, obtain consent from your Insurer first.
There is a common misconception that it is only the receipt of a lawyer’s documents that constitute a ‘claim’ and should be notified. However, the duty of an Insured is to notify all ‘Circumstances’ which are ‘likely’ or ‘may’ give rise to a claim.
CLAIMS CHECKLIST
1. What does the policy state in terms of the notification form and its provisions?
2. Is the Insured ‘aware’ of the incidents giving rise to the circumstance and when did it arise?
3. Has the notification time requirement been met?
4. Does the materiality of the circumstance objectively meet the threshold test of being “likely to” or “may” give rise to a claim?
5. Has the Insured complied with the policy Terms & Conditions and is there sufficient causal connection between the circumstance and claim?
6. If the Insured is in any doubt about what constitutes a notification, the Broker should be consulted immediately.
Please note that all Insurers’ policies are different on what needs to be notified and when. Failure to comply with the terms of your insurance policy could prejudice your position, and Insurers would be within their rights to repudiate and deny liability which could leave you seriously out of pocket.
For more information from Claims Corner,
please call your Lark Claims Handler.
020 7543 2815
Directors & Officers
LiabilityWhat is a Claim?
What constitutes a Circumstance?
Daniel LimD A N I E L . L I M @ L A R K I N S U R A N C E . C O . U K
10
In less than three years, the majority of landlords will have to make sure that their privately rented properties reach a specific
minimum energy efficiency level, otherwise they will face the prospect of those properties sitting empty. As the Government had a duty, a compulsory requirement of The Energy Act 2011, to improve the energy efficiency of properties in the private rented sector, it created The Energy Efficiency Regulations (2015).
From 1 April 2016, tenants will be able to request their landlord to carry out reasonable energy efficiency enhancements to improve the property’s Energy Performance Certificate (EPC) rating. The landlord cannot refuse to carry out the necessary works if it can be wholly financed, at no cost to the landlord, by means of funding provided by central government, a local authority or any other person; can be wholly funded by the tenant; or can be financed by a combination of those two arrangements.
From 1 April 2018, private domestic and non-domestic landlords will not be allowed to let out their property if it does not have a minimum EPC rating of an ‘E’. This applies to any new tenancy or any renewal of an existing tenancy agreement.
From 1 April 2020, the requirements will apply to all properties in the private rented sector, including existing lets in the domestic sector.
From 1 April 2023, these requirements will apply to all private rented sector properties, including existing lettings in the non-domestic sector. Any property covered by a lease of more than six months and with a leasehold of less than 99 years will also be covered by the Regulations.
THERE ARE A NUMBER OF EXEMPTIONS THAT LANDLORDS CAN CITE:
The property is unable to be brought up to the standard as the measures are not cost effective within a seven year payback or under the Green Deal’s Golden Rule.
The tenant refuses consent.
The landlord is unable to obtain consent from a third party.
The works required to bring the property up to the ‘E’ level would devalue the property by more than 5% of market value.
Landlords who wish to improve the energy efficiency of their property have the chance to access funding support from a variety of sources. As there is long lead time on this legislation it provides plenty of time for landlords and agencies to put in place processes and procedures to make sure they are compliant by the time it takes effect.
The Government is taking this requirement very seriously and, where a domestic property has been let which does not meet the minimum standard, the tenancy will remain valid but the landlord will face a fine of up to £5,000 and a publication penalty consisting of publication on the Private Rented Sector (PRS) Exemptions Register detailing the breach. The fines can be much greater for non-
domestic properties.
For breaches in relation to non-domestic private rented property, fines could exceed £5,000 ranging from 10% of the rateable value of the property (subject to a maximum of £50,000) up to £10,000 or 20% of the rateable value of the property (whichever is
the greater) (maximum £150,000). This, of course, depends on the regulation breached. The publication penalty would also be in addition.
That’s why it’s crucial to remember that the responsibility for all of the property’s compliance requirements ultimately rests with the owner. Compliance is critical and should be taken very seriously – it can only go badly if it isn’t!
Keeping up to date with all the latest rules and regulations can be difficult, that’s why at Lark we endeavour to keep our clients informed about changes which may affect them.
For more information please call
your Lark Account Handler.
020 7543 2856
A l l y o u N E E D t o K N O W a b o u tl a n d l o r d ’s r e s p o n s i b i l i t i e s w h e n i t c o m e s
t o e n e r g y e f f i c i e n c y .
HipsonPA U L . H I P S O N @ L A R K I N S U R A N C E . C O . U K
Paul
Energy Efficient?
FINES COULD EXCEED £5,000
11
12
There is no doubt that Cyber Threat is the topic of the moment. It features on the agenda of most board and audit
committee meetings and it is on the minds of many organisations.
Information is the life blood of an organisation and we are all increasingly more reliant upon technology and information assets. In the UK, cyber security has been defined as a Tier 1 threat to the nation, making it a strategic risk management issue for all organisations. In mid 2013, MI5 wrote to the board of every FTSE350 company urging them to ensure that they were taking adequate steps to protect themselves.
WHAT IS ‘THE CYBER THREAT’?
This is the million dollar question. And you won’t get the same answer twice.
Cyber Threat is a convenient label applied to the multitude of risks to data, information and the systems which store and process it. These risks could be precipitated by events or actions as varied as external hacking, social engineering, a compromised third-party supplier or an employee leaking information. These are diverse activities that are likely to require a very different response to remediation and ongoing management.
SHOULD WE BE CONCERNED ABOUT THE CYBER THREAT?
The answer, categorically, is ‘Yes!’. Globally, with security incidents on the rise, reputation, regulatory status and financial well-being are more at risk now than ever before.
No matter what size your business is, cyber criminals are opportunists and will always be on the lookout for soft targets. They know larger organisations have big security budgets and will, usually, have better detection
capabilities that are more likely to spot and deal with a security breach before it escalates.
Latest government figures indicate that 81% of large corporations and 60% of small businesses reported a cyber breach, with each breach estimated to cost between £600,000 to £1.15m for large businesses and £65,000 to £115,000 for smaller companies.
UNDERSTAND THE RISKS
Organisations clearly need to respond to the threat. But where to start? Technology companies will tell you to buy their software whilst IT service companies will tell you to outsource your IT to them. Software, security tools, penetration testing and transferring some of the risk to a third-party (via outsourcing) may be part of the solution but, applied in isolation to the Cyber Threat, there is a very real risk of missing the point. The best technology and tools can be undermined by weaknesses in basic security practices or by a flawed corporate culture.
Today’s cyber criminals are adopting approaches which step away from the purely technical and look to exploit weaknesses in the way that organisations manage, control and interact with their information. This means that the corporate approach also needs to shift from one of ‘implementing security’ to one of ‘information risk management’. The foundations of good information and security governance include:
• User access management
• Clear policies on security, e.g. acceptable system and social media use
• Staff security training and awareness
• Oversight of third party suppliers
• Timely application of software security updates
Fundamentally, addressing the Cyber Threat means going back to basics and understanding
your organisation’s information (where it is and how it is used), identifying risks to your information assets and ensuring that the right measures are adopted to mitigate risks to within acceptable levels (balancing cost vs risk). That is why investment in people, skills and robust policies and processes is crucial. The Cyber Threat is a problem for the entire business to solve – not just IT.
STAY ON TOP
Putting it simply, the approach that should be taken in building a robust Cyber Security Strategy has not really changed much in the past 10 years.
To be truly effective, an organisation should make sure that they consult and collaborate with their peers and utilise the ‘weapons’ that are available to them, whether these be close to hand (e.g. policies, procedures, audits) or those specifically designed by security service vendors to keep the bad guys at bay.
Even if you successfully fight off a Cyber Threat you can be sure that they will return; bigger and badder than before. So, make sure your organisation is always prepared.
For more information on the dangers of cyber-attacks, and how Cyber Liability Insurance can protect your business interest, please contact Martin Camp:
020 7543 2806
Cyber-Attack Protect yourself from the fallout
M a r k C h i l d , P a r t n e r a t K i n g s t o n S m i t h C o n s u l t i n g L L P, t a l k s t o u s a b o u t h o w w e c a n h e a d o f f t h e t h r e a t p o s e d
b y C y b e r a t t a c k s
13
COMPANIES NEED TO PREPARE FOR A DOOMSDAY SCENARIO - AT THE VERY LEAST TO ENSURE THAT, IF AND WHEN A BREACH
OCCURS, A STRATEGY IS IN PLACE
14
D i v i s i o n a l D i r e c t o r , L e e S c o t t , t a l k s a b o u t t h e d a n g e r s o f u n d e r i n s u r a n c e
Cover Spotlight
15
u n d e r
Valued?A l l y o u N E E D t o K N O W a b o u tt h e r i s k s o f u n d e r i n s u r a n c e . . .
Lee ScottL E E . S C O T T @ L A R K I N S U R A N C E . C O . U K
In our first edition of Cover Spotlight we talk to Lee Scott, Divisional Director at Lark’s Croydon office, about ‘Underinsurance’- a
subject which is becoming a growing concern for many commercial businesses.
In a tough economic climate, reports show that more than 50% of commercial property is not fully insured, with some only insured for half the amount it should be. Not having adequate limits and cover in place can jeopardise any businesses chance of survival and speed of recovery following a major loss.
Having a comprehensive insurance programme in place is only the first step, this needs to go hand in hand with continually assessing sums insured and ensuring accurate levels of cover are in place. This will help businesses recover faster and remain in a strong commercial position following a major claim.
WHAT IS UNDERINSURANCE?
In summary, underinsurance occurs when either the sums insured on a policy do not represent the current value of the items at risk or where limits within a policy are inadequate for a client’s needs. It is important to remember that any sum insured should represent the full extent of the risk. For example, the buildings sum insured should not only cover the building materials and labour costs required to rebuild the property but it also needs to cover any debris removal costs, architects’ fees, local authority fees and so on.
Unfortunately if all these factors are not taken into consideration, in the event of a claim, being underinsured will result in a financial loss to the client as insurers will apply average to any losses, but what does this actually mean?
Average works by reducing the amount of the claim by the same amount of underinsurance, for example:
A client’s building is insured for £ 500,000 and a fire occurs causing £ 200,000 worth of damage. If the correct value of the building is actually £ 750,000 Insurers will consider that the client has only insured the building for two thirds of the risk and as such will reduce the claim payment by a third. Therefore the initial £ 200,000 claim would be reduced by £66,660 and settled at £ 133,340 LESS any policy excess that would then be applied; this illustrates the financial loss that will be incurred by the client.
HOW TO AVOID UNDERINSURANCE
There are some key areas where underinsurance can be especially prevalent. These include, assessing the correct level of business interruption cover (both in terms of calculating Gross Profit for Insurance purposes as well as identifying the correct period of recovery), maintaining an up to date register of all machinery, plant and contents and understanding the replacement value of these items and finally confusion around the market value and rebuild costs for commercial property.
LARK SUPPORT
We will be in contact over the next few months to discuss this issue as it is important we work with our clients to continually assess sums insured and policy limits to avoid the potential of being underinsured. In addition, we can also put our clients in contact with professional valuation companies who can provide further assistance.
Please do not hesitate to contact your Lark Account Handler for more information, also download our PDF document about underinsurance at:
www.larkinsurance.co.uk/commercial/underinsurance
020 8256 4910
SOME BUSINESSES ARE UNDERINSURED BY
MORE THAN 50% AND ON AVERAGE, ACROSS
ALL SECTORS THE LEVEL OF UNDERINSURANCE
IS 20%
16
G r o w i n g u p i n w o r k i n g c l a s s 1 9 6 0 ’s B r i t a i n g a v e m e t h e i n s p i r a t i o n t o c h a m p i o n c h a n g e s i n e q u a l i t y a n d d i v e r s i t y , C h e r i e B l a i r Q C t e l l s L a r k D i r e c t o r , J u l i e W h i t e h e a d , i n a n
e x c l u s i v e i n t e r v i e w
Julie WhiteheadJ U L I E . W H I T E H E A D @ L A R K I N S U R A N C E . C O . U K
Cherie Blair’s mother, Gale, worked in a fish and chip shop to make ends meet when her husband, the actor Tony
Booth, left her for another woman.
Gale, along with Cherie, eight, and her sister Lyndsey, six, had no choice but to continue living with her in-laws in Liverpool. Eventually she got a job at Lewis’s department store and worked her way up the career ladder but she still could not get a mortgage.
Cherie said: “The Divorce Reform Act was not introduced until 1969 so in those days the bank would only lend money if the man signed for a mortgage. It was absurd because the assumption that my father, a drunk and a womaniser, was more reliable than my mother, was almost unthinkable.”
Cherie’s mother had left school at 14 and made every effort to give her daughters the schooling she had missed.
Cherie, 60, said: “It was quite unusual in 60’s Britain for a woman to be separated from her husband but my mother and grandmother were obsessed with education
and determined we would have the education they were denied. There were lots of books in the house.
“They had high expectations so I worked hard because I wanted to make them proud.
“It was a loving environment. We were not much different to anyone else in Ferndale Road. We played in the street, had a black and white television and were generally sheltered from the consequences of my father’s behaviour because he was in London.”
Booth, the star of the racy Confessions films, including Confessions of a Window Cleaner, and TV sitcom Till Death Us Do Part ‘was not always a good boy’, said Cherie. “Although in some ways, it gave me some training on what to expect with a famous husband.”
Cherie did not start out with a career plan. When she was thinking about university, her first boyfriend’s mother mentioned law. She said, “you are good at debating and drama so why not think about being a lawyer?”
“I managed to get a full scholarship and chose
the London School of Economics (LSE) which was fairly unusual for a girl from my school. The LSE had a radical reputation and though it was a rebellious streak that took me to London, once I got there I found it was the place for me. I loved it.
“It was a huge learning curve in every way and it was the first time I had met people from public school - but I was determined to succeed.
“I chose to focus on human rights – partly because I was interested in the whole women’s thing and there was so much happening at that time. I was also aware there were a lot of differences between those who came from public schools and people like me with a completely different background.
“I graduated in 1975 when the Labour Party had just brought in the Sex Discrimination Act. Times were changing and I was lucky enough to take advantage of that for myself and seize the opportunity to take some of the test cases that led to the development of the Human Rights Act.
Mind
Gapthe
17
Special FeatureD i r e c t o r , J u l i e W h i t e h e a d , t a l k s w i t h C h e r i e
B l a i r a b o u t e q u a l i t y
18
“I remember the women at Ford in Dagenham going on strike. I was always interested in politics but it was usually the men who talked about it among themselves – but my Auntie Audrey was always politically aware so I would discuss things with her, while my teacher, Mrs Speight, encouraged me to join the Labour Party when I had turned 16.
“That was in 1970, when Barbara Castle introduced the Equal Pay Act with a five-year phasing in period, so when I went to university, employment law was one of the pieces of legislation I studied.”
Cherie was called to the Bar in 1976 and in 1995 she became a Queen’s Counsel. She said: “I was the 76th woman and even now only 200 women have been appointed as silks, compared to thousands of men.”
She said: “Look at our members of parliament, too. Only 29% are women. I visit Rwanda with my Foundation and its government has 60% women! Here, nobody says how strange 70% of MPs are men or that only 450 women have ever been MPs, fewer than the men in this single parliament.
“When my husband Tony Blair introduced all-women shortlists in 1997, and as a result at the next election there was a big increase in Labour MPs, the press then called them ‘Blair Babes’, implying that surely unless they were ‘babes’ they could not possibly have been elected.”
Cherie is even less impressed by the forecasts for women’s equality. She said: “The World Economic Forum reports that it will be another 80 years until women reach economic equality with men”.
“There is lots we can do. Diversity in employment is the key to making the best return for investors and for creating a better, more educated workforce.
“We have all the evidence from reports by accountant Ernst & Young and Harvard Business School to show this, not just gender equality but all kinds of equality in the workforce; disability, race, sexual orientation and age. Everyone working together and accepting their differences is much more creative than uniform white, male employees.
“As for quotas for women on boards, I see this as a necessary step, a catalyst for change - not to be in force forever, something just to gain momentum.”
“It has been encouraged in places likes Norway, France and Germany but if we
think we can solve inequality with women on executive boards we are kidding ourselves.”
“Figures for women executive directors on boards are disappointing with about 23.5% in the FTSE 100 and 18% in the FTSE 250.”
Cherie is also aware that one woman on a board cannot bring systematic change. She said: “It does not make much difference with one woman, as she can be an isolated voice, but if you have two or three, say 33%, you start finding a real change and it can be sustainable.”
“I welcome the 25% target but it would not have come about without the threat of compulsory legislation and we cannot be complacent.”
Cherie has also spoken to David Cameron before he was Prime Minister, regarding the gender pay gap, and she says he takes the issue seriously.
She said: “In 2010 all companies of more than 250 employees were required to report their gender pay gap but this was a voluntary code and only five companies did so. It will now be compulsory.
“Girls are doing better at school and performing as well, if not better, at university but after they enter the workplace, within five years men are earning more and accelerating up the career ladder.
“When I was first a young lawyer I was determined to be as good as any male lawyer.
When I started my pupillage at a law firm in the 1970’s, I was in direct competition for a job with a young man. Even though I performed better and had scored better in my studies, it became clear that when the firm was deciding to give one of us a permanent job, they were going to pick the man. I found this incredibly unfair - even the male candidate admitted that I was better suited for the job. The firm, however, missed out in the end, as this man eventually left the law and went in to politics. He also ended up being my husband.
“I would not necessarily recommend what I did. Because I wanted to prove myself, when I had children, I did not take maternity
leave or make any concessions. Now all these provisions are within the rules. There is specific provision for maternity leave, for example. That is right and proper and as it should be.
“Not all women are the same and not all men are the same either. A lot of the changes have benefited men as well as women.”
“Only one per cent of men are taking up paternity leave because they are scared of what might happen to their jobs - so there is a fault in the system. The better companies recognise that an employee has a larger hinterland than just their work and that makes them better people.”
Cherie has high hopes that Hillary Clinton could also bring about great changes from across the pond if she was elected as President of the United States.
Cherie said: “Hillary is a friend and an inspiration. When she failed to be nominated in 2008, she gave a speech about the cracks in the glass ceiling. I would like to see her go through that ceiling.
Her breadth of knowledge and experience over many years in public life make her uniquely qualified to become the first woman president of the USA.”
Although Cherie sees Hillary as an icon, she says her mother and grandmother have been role models and she continues to live by their words: Never let anything defeat you, stand up against adversity and be fearless.
“It took me a long way.”
I LEARNT THAT YOU DON’T SOLVE THE PROBLEMS BY NOT CONCEDING THE
DIFFERENCES - AND THE DIFFERENCES
ARE WHAT MAKE LIFE INTERESTING
IT IS EXTRAORDINARY THAT COMPARED TO A MAN, A WOMAN
TODAY HAS TO WORK FOR 57 DAYS FOR
NOTHING - AND THE GENDER PAY GAP IS EVEN WORSE FOR
WOMEN IN PART TIME WORK
I DO NOT WANT TO WAIT 80 YEARS FOR
EQUALITY
19
CHERIE AND JULIE CONTINUE TO TALK ABOUT THEIR SHARED PASSION FOR CHARITABLE CAUSES
Fighting for equal opportunities has shaped Cherie Blair’s life and her charitable foundation now helps
women build small and growing businesses in 80 countries.
“We focus on the three C’s,” said Cherie. “Confidence, capacity and access to capital.”
More than 125,000 women have benefited from the Cherie Blair Foundation for Women since its formation in 2008 and they are now able to contribute to their own economies and have a stronger voice in their societies.
Cherie said: “I come across so many fantastic things going on across the world and because of my own background I want to help make a difference.
“I am entrepreneurial.”
“As a barrister, I am self-employed so it resonated with me to help other women to help themselves.”
When Ellen Johnson Sirleaf was elected as Africa’s first woman president, in Liberia, I was thrilled to hear a week later that a young girl in an African school who was being told off for being noisy in class said to her teacher “be careful how you speak to me as I might be president one day”. This would never have been dreamed of before then. Isn’t that
wonderful?”
Cherie is also a self-confessed techie. She said: “I am obsessed by technology because I would never have coped as a self-employed barrister, Prime Minister’s wife and mother of three sons and a daughter if I had not been able to use the internet to make my life easier.
“In the 21st century there is so much more we can do through technology and we can accelerate our reach to women so they will not have to wait so long to achieve equality.
“We have a mentoring programme which uses English and an innovative online platform to help women build their computer skills and business knowledge.
“One woman now runs an internet café in Kigali, Rwanda and has a scanning machine so locals can pay their taxes. While I was visiting I commented on one woman’s lovely dress. She said she had learned to make it by watching dressmaking on YouTube. Such resourcefulness is incredible – I don’t think I could do that!
“We encourage women to look at the market and work out the gaps. In Rwanda, we are supporting 15,000 small businesswomen through a project which provides finance literacy and business training. We do it in many different ways and also support savings and loans clubs, sometimes in villages where there is no electricity or running water.
“One woman I spoke to was 22, not married and not particularly happy. She thought saving clubs should not just be for the older women so she borrowed 200 francs from her parents to buy seeds to grow vegetables.
From her profit she bought a pig, which had five piglets, and then she diversified to sell fertiliser.
“As a result she has increased her confidence, she has paid back her parents, pays health insurance for her siblings and has even got engaged.”
www.cherieblairfoundation.org
20
With women, on average, earning just 81p for every pound that a male colleague receives in his pay
cheque, pay equality has still not fully arrived. With the British people’s stoic attitude towards talking about pay, many women will be unaware that they are still earning less than a man doing the same job as them. This is shocking considering that the Equal Pay Act has been in force for over 40 years!
But, things should start to change for the better; consultation was launched on 14 July 2015 for regulations to be introduced in 2016 requiring any organisation with 250 employees or more, to have a mandatory obligation to publish an annual report on gender pay gaps within their organisation. Companies will be expected to publish the difference between men’s and women’s starting salaries; the difference between average basic pay and total average earnings (broken down by grade and job type); and reward components at different levels, e.g. bonuses.
This will force many companies to take a long hard look at their pay scales before they become the victim of scandalous headlines and damaging lawsuits. It is expected that companies failing to comply with the legislation could face a fine in the region of £5,000. Sadly, this is not an amount that will be a huge deterrent to a business adamant about hiding their unbalanced pay scales.
For those organisations that are willing to do something to improve the current situation, here are some examples of best practice advice:
— Make sure you understand what the equalities’ legislation says about terms and conditions of employment.
— Make sure that everyone (managers, employees, and trade unions) understand your pay and benefit systems.
— Have one simple pay system for all your employees.
— Base your pay structure on an objective evaluation of job demands.
— Limit local managerial discretion over all elements of the pay package.
— Check salaries on entry to the organisation, and on entry to other grades, to ensure men are not starting on higher salaries than women. Remember, your responsibility is to provide equal pay, not to match previous salaries.
While the legislation does not currently affect organisations with less than 250 employees it is most likely only a matter of time before this legislation is rolled out to more and more organisations as interested parties push for wider pay transparency within the work place and an end to unequal pay.
There has been resounding approval of
the enforcement of this legislation and it is believed that the overall impact will only be positive and help women continue to close the pay gap. We’re one step closer to equal pay for equal work!
Julie Whitehead
Director
020 7543 2809
Julie WhiteheadJ U L I E . W H I T E H E A D @ L A R K I N S U R A N C E . C O . U K
D i r e c t o r , J u l i e W h i t e h e a d , d i s c u s s e s t h e i n t r o d u c t i o n o f n e w r e g u l a t i o n i n 2 0 1 6
RETIREMENT AGE FOR WOMEN? 80, IF THEY WANT TO EARN AS
MUCH AS MEN
Equal Pay
Equal Work
21
"I do not want to
wait 80 years for
equality"- Cherie Blair
22
Client SpotlightA n e x c l u s i v e i n t e r v i e w w i t h A l e x M c L a u c h l a n , F i n a n c i a l D i r e c t o r o f H a w k s m o o r R e s t a u r a n t s
23
Enjoying iconic status across the City, Hawksmoor has built a reputation for offering the finest steaks in London.
We know, we have tried them. A labour of love to find the perfect beef was the inspiration behind Hawksmoor. They are proud of their achievements, and particularly of coming 12th in the Sunday Times Best Companies and being shortlisted as one of the most sustainable restaurant groups in the country, being awarded a maximum three star rating at the Sustainable Restaurant Awards.
Here we talk to the Finance Director, Alex McLauchlan, about a typical working day at Hawksmoor, where two days are never quite the same…
8 am I drop my daughters off at school and
then look forward to the daily commute from my home in Hertfordshire to our offices in Wapping.
9 am I begin the day reviewing emails, review the sales in our restaurants, look at any reviews from critics, and then plan my action points for the day.
10 am Check in with HO Management teams, and liaise with general managers within the Hawksmoor and Foxglow restaurants.
11 am We are in expansion mode at the moment and this occupies a significant amount of my time, we have recently opened in Manchester, and in advanced talks to extend our brand internationally. I spend time with our lawyers, our insurance brokers and other financial advisors to finalise these arrangements. We are very excited about the prospect of expanding internationally – a well cooked steak has pretty much universal appeal, and whilst this brings different challenges logistically, it will be good to expand the brand and enjoy the travelling that this will bring.
2 pm Lunch and meeting with our suppliers, this week it is with Ginger Pig who supplies our beef to all of our restaurants. Hawksmoor has an ethics culture and we have always prided ourselves on the fact that the animals that our food comes from, have lived a decent life.
4 pm I make a point of dropping into one of our restaurants unannounced. This gives me the opportunity to check out any competition locally, I talk to the staff about how things have been trading for that day and any concerns that they have.
6 pm Once again, time to face the daily commute back to Hertfordshire, and hopefully in time to read to my daughters before bedtime.
020 7543 2815
Account Executive, Daniel Lim, with Alex McLauchlan, Finance Director at Hawksmoor
Alex McLauchlan, FD at Hawksmoor
A day in
the life...L a r k A c c o u n t E x e c u t i v e , D a n i e l L i m , m e e t s w i t h l o n g s t a n d i n g c l i e n t , A l e x M c L a u c h l a n , f r o m H a w k s m o o r
Daniel LimD A N I E L . L I M @ L A R K I N S U R A N C E . C O . U K
24
MAKING CRITICAL ILLNESS SIMPLE FOR EMPLOYERS
Employees’ health and wellbeing is a subject that is moving up the UK boardroom agenda.
With wellbeing and happiness at work often being quoted as being as important and motivational to employees as annual pay, many employers are now taking the time to review their employee benefit packages to help recruit and retain the best staff.
One of the benefits on offer is Critical Illness cover. This product has been around for some time and supports an employee in the event of a critical condition such as cancer, a heart attack or stroke, by paying a lump sum which can ease some of the financial pressure during their recovery.
There are 63,000 people living in the UK with a critical condition, many of whom want to live as normal a life as possible including being able to return to work. With one in four women and one in five men being affected before retirement, providing this cover demonstrates a tangible interest in
staff wellbeing whilst helping employees to recover and return to a normal working life.
Traditional Group Critical Illness cover has been criticised by some employers for being too complex, listing many conditions which add little or no value and excluding pre-existing conditions.
That is why leading group risk insurer Unum has worked hard to develop a truly simple policy.
SimpliCIty Critical Illness by Unum provides cover for the ten conditions shown to be the majority of all critical illness claims.
Whilst an employee will not be able to claim for a condition they have when the policy starts, once all clear, they will be able to claim for a new occurrence of the same condition.
Sums assured can be set by employers up to a modest limit helping claimants with the expense of treatment and recovery.
As a preferred partner of Unum, Lark Employee Benefits is one of a select few providers who can offer this market leading product to their clients.
“It’s fantastic to be able to offer such an effective product with so many options. Working with an industry leader such as Unum gives us and our clients real confidence in the solution we are providing.” - Samantha Mistry, Director of Employee Benefits at Lark.
To find out more about SimpliCIty Critical Illness by Unum or to review your employee benefits offering please contact Samantha Mistry.
020 7543 2818
Sam MistryS A M . M I S T R Y @ L A R K I N S U R A N C E . C O . U K
SimpliCItyC r i t i c a l I l l n e s s c o v e r m a d e s i m p l e
25
INSURANCE PREMIUM TAX INCREASE IS COMING!
In the 2015 summer budget, Chancellor George Osborne announced that Insurance Premium Tax (IPT) will
increase from 6% to 9.5% as of November 2015.
When introduced in 1996, it was set at a flat rate of 2.5% and has steadily increased over the years. The proposed increase from 6 to 9.5% represents an increase of 58%, making it the most significant rise for many years and is expected to generate an additional £1.75bn a year.
The Chancellor argued that Britain’s insurance premium tax was well below that of other countries and an increase would affect only one-fifth of all premiums. Currently the level of IPT in the UK in comparison to mainland Europe is reasonably low at 6%.
For example in Germany the tax applicable is 19% and in Italy it is 22.25%. The British Insurance Brokers Association (BIBA) slammed the move as a “stealth tax” on insurance policies that would hit millions of ordinary households. Steve White, BIBA chief executive also commented that the increase in IPT “seems counterintuitive” and the government is “taking measures which will add to the cost – effectively taxing protection.”
Once the increase takes place it is important that you consider the following:
Policies incepted or renewed on or after 1/11/2015:
• Will attract the new IPT rate of 9.5% regardless of when the quote was provided or at any rate guarantees that may apply
• Will attract the new IPT rate of 9.5% for any mid-term change which results in payment of an additional premium
• Will attract the new IPT rate of 9.5% rebate for any mid-term adjustment or cancellation resulting in a refund of premium
Policies incepted or renewed prior to 1/11/2015:
• Will attract the ‘old’ rate of IPT of 6% provided that the premium is paid by 29/02/2016
• Where the mid-term change takes place between 1/11/2015 - 29/02/2016 (inclusive) which results in an additional premium the ‘old’ IPT rate of 6% may be applied to that additional premium
• Where a mid-term change or cancellation takes place between 1/11-2015 - 29/02/2016 (inclusive) which results in a refund of the premium, the ‘old’ IPT rate of 6% applies to that refund of premium (HMRC will not allow more IPT to be refunded than was originally paid)
Additional premiums on or after 1/03/2016:
• Where mid-term change takes place on or after 1/03/2016 which results in an additional premium the new IPT rate of 9.5% applies to that additional premium
Refunds on or after 1/03/2016:
• Regardless of the date of change, where one or more mid-term adjustment takes place and different rates of IPT have been applied (e.g. 6% on inception premium but 9.5% for a mid-term adjustment) or cancellation takes place that results in a refund of premium being due, ideally IPT will be apportioned.
• However HMRC accept that computer systems may be unable to do so, in which case the overriding consideration is that the rebated IPT must not exceed the rate at which IPT was originally paid. Therefore if the computer system is unable to apportion IPT the rate of IPT on refund of premium will be at the
6% rate.
Anti Forestalling Provisions:
There are also anti-forestalling provisions to deal with attempts to avoid the increased rate by extending cover, advancing premium payments or applying additional premiums.
For more information on how the increase may impact your insurance payments please contact your Account Handler at Lark.
020 7543 2842
Adam FulcherA D A M . F U L C H E R @ L A R K I N S U R A N C E . C O . U K
IPT BulletinI n s u r a n c e P r e m i u m Ta x i n c r e a s e .
PREPARE FOR THE FUTURE
BY BUDGETING CORRECTLY TAKING INTO ACCOUNT THE
IMPACT THE INCREASE WILL HAVE ON YOUR
BUSINESS
26
INSURANCE RISK SOLUTIONS JOIN LARK (GROUP) LIMITED
Insurance Risk Solutions (IRS) is a CII Chartered Insurance Broker that joined the Lark (Group) Limited in July 2014.
The directors and many longstanding staff at IRS have worked in the picturesque and historic Suffolk market town of Bury St Edmunds for over 25 years, from where we have been providing commercial insurance solutions to a diverse range of trades and industries across the region. With both companies sharing a like-minded approach to staff, the insurance market place and client service, the integration has been seamless.
By joining Lark, we have not only helped grow
their influence within East Anglia but our current and future clients now have access to additional products and services that Lark have brought to the table.
My colleague, Simon Wilding, IRS Commercial Director, summed it up best when he said, “Lark has broadened the range of products and services available to our clients and prospects to make the overall proposition even stronger.”
In other good news, all 26 members of the staff and management team have remained with the business and this ensures continuity of contact and service for our loyal client base. As the senior team has worked together for more than 20 years, this is great news. We are all very much looking forward to taking all opportunities to develop and progress our
careers within Lark.
For the time being, IRS will continue to trade under our existing brand but in January 2016 we will finally complete the merger with Lark and take advantage of their award winning brand name, something which everyone here is looking forward to.
So, at IRS, we look forward to our future with Lark with great enthusiasm, building on our success to date for the benefit of all.
Paul WisbeyPA U L . W I S B E Y @ I N S U R A N C E R I S K . C O . U K
IRS joins the nest
27
It’s been a busy, exciting year at Lark, so we thought we would use our first edition of Larklink as an opportunity to share with
you some of the things we have been doing so far in 2015.
LARK CORPORATE GOLF DAY The annual Lark golf day took place in May on a wet and windy Wildernesse golf course in Kent. This year we had 40 attendees taking part that ranged from staff, insurers and clients, Andrew Lawrence, David Bramwell and Dean Wright managed to battle through the weather to take the prestigious title!
NOT FORGOTTEN ASSOCIATION (NFA) AVIVA COMMUNITY FUND WINNERS!
As our chosen corporate charity all our staff continue to raise much needed funding for the NFA. The charity provides leisure and recreation for the benefit of serving and ex-service personnel who have been wounded or sustained permanent injuries.
Lark started working with the NFA just over two years ago and to date have raised over £ 30,000 to improve the lives of the charity beneficiaries. Our staff get involved in a wide
range of fund raising activities from cake baking, bike riding and skydiving!
In addition, we recently submitted an entry to the Aviva Community Fund on behalf of the NFA to try and obtain £5,000 of additional funding. We recently found out much to our delight that our submission won and we secured £5,000 of additional funding for the charity.
CORPORATE ACCOUNT EXECUTIVE DANIEL LIM MAKES MODELLING DEBUT
PEDAL POWER FROM CALUM DUNNING!
On 15 July Calum a Commercial Account Executive in our London office, set off from Land’s End in Cornwall, beginning a two week cycle to John O’Groats. As an avid cyclist, Calum committed to joining the ride in March as a holiday challenge but also as an opportunity to raise money alongside his brother and brother in law.
Calum successfully completed the ride and raised £300 for the NFA. Our favourite quote from his regular updates was “Two more days to go, its exhilarating, the scenery, the wind, in fact the whole journey!”
LARK GROUP WIN ‘PRIVATE CLIENTS BROKER OF THE YEAR’ FOR A THIRD CONSECUTIVE YEAR!
Life at LarkK e e p u p w i t h a l l t h e l a t e s t n e w s i n v o l v i n g
L a r k G r o u p
BramfordM I C H A E L . B R A M F O R D @ L A R K I N S U R A N C E . C O . U K
Mike
Daniel Lim from our London commercial team had the opportunity to appear as the cover photo on all the CII promotional material.
We are delighted to announce that we have been awarded “Private Clients Broker of the year” for a third successive year at the UK Broker Awards.
Your partner in professionalism• Membership
• Qualifications
• CPDscheme
• Globallyrecogniseddesignations
• IndividualandcorporateCharteredstatus
• Onlinetechnicalandmarketdata
www.cii.co.uk
Chartered Insurance Institute
DanielLimACIICharteredInsurancePractitionerAccountExecutive,Lark(Group)Ltd
28
INSUR ANCE MADE TO MEASURE
LARK EMPLOYEE BENEFITS,
BASED IN THE CITY OF LONDON
We pride ourselves on quality personal service and our honest, loyal and professional approach. We draw on a wealth of experience and technical knowledge to ensure that our clients receive specialised and comprehensive advice.
Working closely with you to gain a full understanding of your business, we will plan and implement a suitable benefit package, according to both budget and staff profile. We select a fitting provider in the market and relieve you of the administrative burdens of running an employee benefits scheme.
For more information, call Samantha Mistry on 0207 543 2818or email [email protected]
@larkinsurance Lark (Group) Limited
We are authorised by the Financial Conduct Authority in the provision of Life Assurance, Investments and Pensions.
29
GET IN TOUCH
SAMANTHA MISTRY
Employee Benefits
London
07984 786719
0207 543 2818
MICHELLE EINCHCOMB
Employee Benefits
London
020 7543 2861
30
STUART WILLIAMSON
Divisional Director
Farnborough
01252 359 070
07977 553 939
LEE SCOTT
Divisional Director
Croydon
0208 256 4910
07990 563 792
AMANDA JOLLEY
Divisional Director
Colchester
01206 771 403
07970 436 407
MARK WOODWARD
Managing Director
London
0207 543 2874
07977 553 936
JULIE WHITEHEAD
Director
London
0207 543 2809
07802 589 424
ROBERT KEENE
Associate Director
Maidstone
07968 853 098
ADAM FULCHER
Divisional Director
London
0207 543 2842
07989 422 427
MARTIN CAMP
Head of New Business
London
020 7543 2806
07971 271 436
RICHARD GRAHAM
Divisional Director - Maidstone/Claims
Maidstone
01622 350 811
GEOFF HALES
Risk Manager
07891 602 052
SIMON WILDING
Commercial Director
Bury St Edmunds
01284 777 559
07983 431 601
OUR PEOPLE
31
@larkinsurance Lark (Group) Limited
@larkinsurance
Lark (Group) Limited
L A R K I N S U R A N C E . C O . U K
IBEX HOUSE42-47 Minories London EC3N 1DY
CROYDON28 Dingwall Road Croydon, Surrey CR0 2NH
WIGHAM HOUSEWakering Road Barking, Essex IG11 8PJ
CENTURY HOUSENorth Station Road Colchester, Essex CO1 1RE
COLMAN HOUSEKing Street Maidstone, Kent ME15 1DN
WESTMEAD HOUSEFarnborough Hampshire GU14 7LP
DETTINGEN HOUSEBury St Edmunds Suffolk IP33 3TU
