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Unpickling costly planning obligations

Steeles Law Head of Planning & Environment David Merson looks at the Coalition’s proposals to revise the planning obligations regime to try and help kick-start stalled development proposals.

It is suggested that some two thirds of approved building projects in the last five years have either been dumped or stalled as a result of planning obligation costs making development proposals uneconomic in the wake of the credit crunch and subsequent recession.

The Secretary of State for Communities and Local Government, Eric Pickles, is therefore sending ‘troubleshooters’ into 13 local planning authorities to see if re-opening and re-negotiating section 106 planning obligation deals could provide a means of getting some projects back on track.

Coupled with this, the Coalition has announced a consultation exercise involving amendments to the Town and Country Planning (Modification and Discharge of Planning Obligations) Regulations 1992 SI 1992/2832.

The proposal will allow planning obligations entered into prior to 6th April 2010 to be re-negotiated in order to unlock development projects which were negotiated in more buoyant economic conditions but which are currently not economically viable.

Section 106 of the Town Country Planning Act 1990 (as amended) allows local planning authorities, usually before granting planning permission, to enter into planning obligations with developers. Those obligations can be voluntarily renegotiated at any time but, under the terms of the Regulations and absent any agreement, can be subject to a formal application process to reconsider the terms when it is five years old. Appeal provisions apply where such an application has been refused.

It is anticipated that the new regime will operate to allow planning obligations entered into on or before the relevant date to be re-negotiated. This provision removes the five-year restriction in the current Regulations from those planning obligations but those more recent planning obligations entered into after that date will not be able to benefit from this change. They must either be re-negotiated by agreement or wait until the expiration of the five-year period and then go through the existing formal modification and discharge procedure.

Developers looking to rely on the revised provisions, if and when enacted, will still need to ensure that the substantive legal test is met and there will, according to the consultation document, need to be strong justification for any change(s) sought. The modified obligation must still be acceptable in that it must still be necessary to make the development acceptable in planning terms.

Note however that local planning authorities cannot be forced to re-negotiate planning obligations. They would be expected to act reasonably and to consider and determine such an application applying proper planning considerations. But they might refuse to do so or they might conclude that there was still clear justification for the obligation to remain unmodified. This would engage the appeal provisions and could also, where the relevant grounds arose, permit an application for judicial review.

Details of the consultation exercise can be found here. The consultation period runs until 8th October 2012.

If you require further information or advice on any issues raised in this article or any other planning & environmental matter please contact David Merson on 020 7421 1720 or dmerson@steeleslaw.co.uk

Interest Rate Hedging Products – An Update

Ian Robotham, Associate in the Dispute Resolution team at Steeles Law, reports on recent developments on the “Interest Rate Swap Scandal” that has become big news over recent months and gives his opinion on matters.

Update

Since first reported by Nigel Lubbock, Head of the Company and Commercial team at Steeles Law in 2010 (click here for link to that article), complaints and allegations against the country’s major financial institutions that they mis-sold derivative (hedge) products to SME’s have gathered pace.

Recently, one particular broadsheet newspaper has given significant media coverage to the issue and a self-help action group of affected SME’s has been set up to champion the cause for its members. In addition, MP’s have debated the issue in the House of Commons and litigation continues in the UK Courts.

All of the above culminated in a two month review of the issue by the regulator, the Financial Services Authority (FSA), the results of which were issued in a report published on its website on 29 June 2012.

Outcome of the Review

In its review, the FSA found serious failings in the sale of interest rate hedging products by the major financial institutions.

In particular, the FSA found concerns regarding (a) inappropriate sales of more complex varieties of interest rate products, in particular Structured Collar products (click here for a link to a previous article by Steeles Law in which we explained the broad categories of products in more detail), and (b) poor sales practices in the selling of other interest rate hedging products.

The FSA further found that, where sold to ‘non-sophisticated’ customers (see further below for a definition in this regard) who may lack expertise and understanding of the product, the sale of some interest rate hedging products may be inappropriate.

To attempt to resolve the above concerns, the FSA has agreed with the four largest UK retail banks (those being Barclays, HSBC, Lloyds and RBS) that they will:-

(i) provide fair and reasonable redress to non-sophisticated customers who were sold Structured Collars on or after 1 December 2001;

(ii) review sales to non-sophisticated customers of other interest rate hedging products (except Caps or Structured Collars) sold on or after 1 December 2001; and

(iii) review the sale of Caps if a complaint is made by a non-sophisticated customer.

These steps are to be carried out under the scrutiny of an independent reviewer overseen by the FSA.

The following link will take you to the FSA’s full review:-

https://www.fsa.gov.uk/static/pubs/other/interest-rate-hedging-products.pdf

In addition, on 23 July 2012, the FSA announced that 7 other UK banks (Allied Irish (UK), Bank of Ireland, Clydesdale and Yorkshire banks, Co-operative Bank, Northern Bank and Santander UK) have also agreed to the same resolution as the four major UK banks.

In its review, the FSA envisages a process whereby the banks; appoint an independent reviewer, contact customers it deems those customers fall within the scope of the agreement with the FSA (i.e. non-sophisticated customers), provide redress where appropriate and review the sales of other interest rate products (again providing redress where appropriate).

Comments

In our opinion, the review is to be welcomed. The FSA has identified that there clearly is an issue here and has at least taken some steps to remedy. We hope that the review will result in the appropriate financial recompense that all victims of mis-selling are entitled to.

However, the review, in our opinion lacks bite and leaves a significant number of loose ends.

Non-sophisticated customers

To define “non-sophisticated customers”, the FSA has followed the criteria used in the Companies Act 2006 for classifying companies that are subject to the small companies regime. Therefore, a customer would be deemed non-sophisticated if it did not meet two of the following three criteria at the time the product was sold:-

1. A turnover of more that £6.5m 2. A balance sheet total of £3.26m 3. More than 50 employees.

In addition, the FSA has allowed the bank to categorise a customer as “sophisticated” even if it does not fall within the above definition if the bank can demonstrate that at the time of sale the customer had the necessary experience and knowledge to understand the product.

However, what if the customer does not agree with the bank’s allocation to a category? For example, what if the bank categorises a customer as sophisticated (so as to fall outside of the review) but the customer feels he should be deemed non-sophisticated? The bank’s assessment will be scrutinised by the independent reviewer. However, where there remains a dispute, the FSA envisages the customer will have to complain to the bank in person and, if that does not satisfactorily resolve the issue, make a further complaint to the Financial Ombudsman Service (FOS). To be eligible to use this service you must have a turnover of less than €2m and fewer than 10 employees. All of which will take time (time a customer may not have, for reasons given below).

Sophisticated customers

If you are a sophisticated customer (on the definition above), you fall outside of the review. This is even the case if the bank previously classified you as a retail or private customer for regulatory purposes.

If you have been mis-sold a financial product, you will have to pursue the bank’s internal complaints procedure and, if not resolved satisfactorily, complain to the FOS, if you are eligible to do so. If you are not eligible to do so, you will have to take formal legal action through the Courts, all of which will take time.

Redress

The redress is to be calculated on the basis of what is fair and reasonable. However, the basis of the calculation of what is fair and reasonable has not been addressed. What happens if (we would say when) what a customer considers to be fair and reasonable (a full refund plus any consequential losses) is considerably different than what a bank considers to be fair and reasonable (for example redress based on an alternative fixed rate product)?

If the parties cannot agree on the level of redress, the customer either has to refer his complaint to the FSO or, if not eligible, will have to take formal legal action.

Insolvency of Customers

What if the customer has become insolvent since the product was taken out?

If a limited company has been dissolved, there is no legal entity to which any redress can be paid. Interested parties will need to take legal advice about whether they can have the limited company restored to the Companies House Register.

Timescales

Perhaps the biggest “loose end” of all is that the FSA has given no time limit within which the banks are required to fulfil their obligations under the agreement.

Whilst the banks are obliged to look at all hedge agreements sold on or after 1 December 2001, customers with a complaint will have to be mindful of limitation issues in the event that they do not reach a settlement with the banks.

It is important to bear in mind that the majority of these sales took place between 2006 and 2008. The Limitation Act 1980 provides that all contract/negligence claims must be commenced not more than 6 years from the date the action arose. In most cases, date the action arose is likely to be the inception date of the product (but there may other factors which could bring this date forward).

Those customers with complaints must be aware that, should there be any disagreement in relation to any/all of the factors referred to above, they will not be able to obtain legal assistance from the Courts once 6 years have elapsed from the date the action arose. This is so even if those loose ends referred to above have not been resolved and would leave complainants at the mercy of the banks (and the independent reviewer) if claims are not issued at Court by the relevant limitation date.

Conclusion

There are still significant potential problems for customers with complaints of mis-selling against banks. There is continued uncertainty and potential for disagreement in relation to a number of areas that may require court action to resolve. Crucially, the inability to successfully pursue a claim through Court after limitation expires means customers with complaints should not delay in contacting us to obtain urgent legal advice. We are able to quickly clarify clients’ positions and commence legal action to protect them should it be necessary.

At Steeles Law, we have acted, and continue to act, on behalf of a number of customers with complaints against banks and have significant experience with these disputes. We continue to act for those clients that have issued claims at Court and provide swift, assured and commercial legal advice to SME’s (and individuals). Do not hesitate to call us should you require legal assistance in this regard.

Ian Robotham

If you do require assistance please click here for Ian Robotham’s contact details and here for Nigel Lubbock’s contact details.

TMS helps Bruno celebrate life as a Pageantmaster

Bruno Peek’s remarkable life as a national and international Pageantmaster over more than 30 years has been brought to life in a colourful and illustrative new website from TMS Media.

It follows one of the Norfolk man’s proudest and most spectacular moments as he inspired and coordinated the lighting of more than 4,200 beacons around the world on June 4th 2012 in celebration of The Queen’s Diamond Jubilee.

Bruno had the honour of passing the Jubilee Crystal Diamond to The Queen that night to enable her to light the National beacon at the end of the BBC concert, watched by a TV audience of millions.

But the website, masterminded by TMS Media in Great Yarmouth, captures his story right back to his first key commission in 1981 when he organised Operation Sea Fire, a chain of 90 beacon fires lit around our coast to launch Maritime England for the English Tourist Board.

Since then he has guided pageants and events across the country and in Europe and Sri Lanka and is keen that all his experience and expertise should be channelled into future projects.

For the last 12 years TMS art director Nick Marshall has been chronicling those events and that personal profile of Bruno’s life forms the basis of the website. In recent years, he was a key figure in The Fly a Flag for Our Armed Forces initiative and the Great Poppy Party Weekend.

“The website simply tells an online audience who I am and what I can do – and it is something I want to continue doing to involve as many people as possible in some of the most significant and important occasions across Britain or abroad,” said Bruno, who lives in Gorleston.

TMS managing director Steve Scott added: “People are sometimes surprised that Bruno hits the headlines so often. But that is because he has spent decades at the helm of headline-hitting events which encourage thousands of people to join in and enjoy national celebrations.”

Visit: www.brunopeek.co.uk

LP attends British Franchising Association (bfa) Roundtable discussion on Thursday 19 July 2012

Vicki Mitman, a solicitor in the firm’s Franchising team, recently attended the bfa roundtable discussions in Warwick. The roundtable discussions included:

  • Franchisee profiling
  • Local marketing
  • Monitoring franchisee performance
  • Ongoing training and support
  • Recruiting the right franchisees
  • Development of online tools

Each roundtable discussion was chaired by a member of the bfa who introduced the topic and discussed their personal experiences. Members of each group were encouraged to share their knowledge and experiences of a particular issue and could ask questions to gain insight and different approaches from other bfa members and affiliates. The topics discussed created lots of interest and produced lively discussions. The break-out groups included both young and mature franchisors and affiliated consultants, accountants, bankers and lawyers.

Leathes Prior is an affiliate member of the bfa and has specialised in franchising for over 30 years.

Airport introduces new parking arrangements

Norwich International and NCP have worked closely together to implement changes within the short stay car park, to make life easier and maintain safety of customers, staff and visitors.

A new specific ‘drop off’ area has been created within the short stay car park for customers – both passengers and those bringing people and picking them up from the airport, to deter drivers from stopping in unauthorised areas and to also help ease congestion at busy times within the car park. The first 10 minutes are free of charge, with standard rates applying thereafter.

The new area is clearly signed; anyone coming to the airport should look carefully for the signs indicating where they should go, to either the drop off area, short stay or long stay car parking.

Mark Kraft, business manager at NCP commented: “NCP is always looking at ways to improve our customer experience when using our car parks, and it became very clear from customer feedback that a drop off lane for passengers arriving at the airport would be really helpful. This way we reduce congestion points for everyone, and make the process as seamless as possible.”

Continuity of Employment under Zero Hours Contract

Employers using zero hours contracts should be aware of a recent decision of the Employment Appeal Tribunal (EAT), in which it was held that individuals engaged under such a contract had continuity of employment. Professional support lawyer Elizabeth Stevens reports.

This case concerned a group of care workers, employed to provide 24 hour care to a severely disabled woman. The contract for the provision of the care service between their employer, Carewatch Care Services Ltd (Carewatch), and the local primary care trust was terminated and a new contract was entered into with Pulse Healthcare Limited (Pulse). The individuals who were engaged to provide the care claimed that their employment transferred to Pulse under the provisions of TUPE.

Pulse denied that the claimants were employees on the basis that they were engaged under a contract headed “Zero Hours Contract Agreement”, which included a provision stating that they were free to work for other employers. Pulse therefore claimed that the ‘mutuality of obligation’ necessary for an employment relationship did not exist. If the claimants were not employees, they would not be covered by the provisions of TUPE.

The employment tribunal disagreed that this reflected the reality of the situation, highlighting the fact that the claimants had worked fixed hours on a regular basis over a number of years. The contract made repeated references to “employment”, and included many of the usual provisions of an employment contract including annual leave, sickness, termination and pension. The individuals were provided with a uniform and were paid on a PAYE basis. The employment tribunal therefore concluded that the individuals were employees, with continuity of employment. Pulse appealed the tribunal’s decision.

The EAT has upheld the tribunal’s decision on the employment status of the claimants. The judge highlighted the evidence demonstrating the critical nature of the care package provided by the claimants and the importance of maintaining an established team of carers for the client. In the judge’s view, it was fanciful to suppose that Carewatch relied on ad hoc arrangements in the provision of such a package. The EAT considered that the tribunal had been justified in its conclusion that the “Zero Hours Contract Agreement” did not reflect the true agreement between the parties.

Comment

This decision reflects the willingness of the courts and tribunals, particularly since the decision of the Supreme Court in Autoclenz v Belcher (see our report), to look beyond the terms of the written agreement to assess the true nature of the relationship between the parties.

It seems clear from the evidence in this case that the contract was not drafted in terms properly consistent with a genuine zero-hours arrangement, and that the reality of the arrangement was consistent with an employment relationship.

The case will now return to the employment tribunal to determine whether the claimants’ employment transferred to Pulse under TUPE.

In practice, the majority of zero-hours contracts will establish an employment relationship. With careful drafting, and depending on the frequency an individual is engaged under such a contract, it might be possible to prevent continuity of employment arising in between each assignment under the contract. However, employers should be very cautious in relying on such contracts if they do not reflect the reality of the arrangement between the parties.

A copy of the EAT judgment is available here

Proposed Child Maintenance System Reform

Emma Alfieri reports on the Government’s plans for a reshaped child maintenance system.

The Government has unveiled detailed plans for a reshaped child maintenance system in Great Britain.

Ministers believe the current system, which costs £0.5bn a year, and focuses purely on collecting and transferring money has proved inefficient and has damaged separated families.

The Government wants to reshape the system so it is focused on supporting families to make their own arrangements which are in the best interests of the children involved.

In order to achieve this, it is proposed that £20m is invested to provide a network of support services to help separated families. The policy document; Supporting Separated Families; Securing Children’s Futures sets out the key improvements.

For the first time, all parents considering applying for child maintenance payments via the state will be invited to discuss their situation and consider possible alternatives. Where appropriate, it will signpost them to community-based support services.

The new statutory maintenance scheme, to be known as the Child Maintenance Service, will take cases where parents cannot make their own arrangements. It is proposed, as well as a £20 application fee, the parent paying maintenance will pay an additional collection fee of 20% on top of each assessed payment.

The parent receiving maintenance will have 7% deducted from each assessed payment. But parents who fail to pay will face additional penalty charges reflecting the cost of enforcement action. For example, it is proposed that a Liability Order from the courts will carry a £300 surcharge, while £200 will be charged if money has to be removed from their bank account via a lump sum Deduction Order.

Both parents will avoid collection fees if the paying parent opts to pay the other directly without use of the collection service. This is designed to build trust between separated couples.

The new Child Maintenance Service will continue to be heavily subsidised but will be faster and fairer and better for parents.

Payments will usually be based on the paying parent’s latest tax-year gross income, reported by HM Revenue & Customs. Use of tax data means assessments will depend less on what parents choose to disclose about their income. Maintenance calculations will be reviewed annually to ensure they remain fair accurate and up to date.

Emma Alfieri, from our family team comments: “This in encouraging news. The additional support for parents to work together can only be useful and the new system should encourage reluctant parents to take their responsibilities seriously”.

For further information please contact Steeles Law’s family team.

Vicarious liability: how much responsibility must an employer bear?

A recent Court of Appeal decision highlights the increasingly far reaching liability of employers for the actions of their employees.

Judgment in JGE v The Trustees of the Portsmouth Roman Catholic Diocesan Trust was handed down on 12 July 2012. The question before the court was whether the church should be responsible for paying damages to a child who was abused by the priest at the church in the 70’s. The court said yes, the (now grown up) victim should be compensated by the church.

To many, it would seem intuitive that a victim of child abuse should be able to recover compensation from the wrongdoing organisation. However, the case actually threw up two key issues, namely: can sexual abuse ever fall within the course of the priest’s duties, and should the church be liable for the priest’s actions?

The first question was relatively straightforward to answer, thanks to a recent decision of the higher court. To be clear, an employer is not merely responsible for what its employees do under direct instruction from the employer. An employer is responsible for all actions which the employee takes which have a sufficiently close connection to the employee’s employment.

So in a 2001 case, Lister v Hesley Hall, the House of Lords confirmed that if an employee was entrusted to look after children, the employer would be liable for sexual abuse by the employee when he was supposed to be looking after them, and the victims could obtain damages from the employer. This was despite sexual abuse clearly being outside of the employee’s duties; his actions were sufficiently closely connected to his employment to pin liability on his employer.

So, in JGE v The Trustees of the Portsmouth Roman Catholic Diocesan Trust, a victim of sexual abuse at the hands of the priest at the church was, in principle, able to claim damages against the bishop to whom the priest answered.

However, the church employed a further argument to avoid liability. The court took expert advice from Roman Catholic academics and found that the priest was not actually an employee (their relationship was intended to be determined by canon law, not civil law, so no employment relationship arose). The court therefore had to decide whether they could extend liability to a situation which was “akin to employment”.

In JGE, the Court of Appeal explicitly said “I confess I have found this difficult to decide”. Although the legal framework is a very real constraint on the court, the judges must have felt huge reluctance to find that a victim of child abuse should not be able to recover damages, particularly when even the barrister for the church described the priest’s actions as “abhorrent”, and rightly too.

The court therefore confirmed that liability in relationships “akin to employment” can be found under specific circumstances, and indeed found such liability in this situation. So, even though the priest was specifically held to not be an employee, the church could still be liable for his actions because he was in a position which was “akin to employment”; the key question being one of control.

This decision does, of course, have huge implications for a modern economy. A business (or, indeed, charitable organisation) can no longer absolve itself of the wrongdoings of another simply because that other is not an employee. A business must ensure that all individuals over whom they exercise sufficient control take proper care in the exercise of their duties (and should probably obtain appropriate insurance), even if the business does not employ them.

Conversely, an injured victim may now be able to obtain compensation from the organisation which had actual control of a situation, and the organisation which might more properly be expected to be insured.

The church has been refused permission to appeal to the Supreme Court, but specifically because that court is due to give judgment in a similar case, Various Claimants v The Catholic Child Welfare Society and the Institute of Brothers of the Christian Schools & ors, very soon (the hearing was on 23 July 2012). That case may provide further clarity.

It may surprise some readers to learn that the above cases have almost no bearing whatsoever on employment law and the rights and obligations as between employers and employees. This fact serves only to show how complex the law of both employment and personal injury is, and proper advice should be sought if in any doubt whatsoever.

Contract Formation via email

With injunctions being served by Facebook, and the first “Twibel” case in the UK (libel duty comments made by Twitter) being won, a recent case regarding contracts made by email highlights how the law is attempting to keep pace with our ever changing forms of media.

Golden Ocean case

The case of Golden Ocean came to the Court of Appeal earlier this year. Golden Ocean claimed that a charterer had failed to honour its obligations to take delivery of the vessel under a guarantee worth in excess of $50 million. The defendants claimed there was no contract or guarantee in existence despite oral communication and an extensive chain of emails. Relying on section 4 of the Statute of Frauds 1677 (which requires that certain types of contracts must be recorded in writing with sufficient detail in order to be legally binding), the defendants argued that the guarantee was incomplete as it was contained over a number of emails which could not be patched together sufficiently, the names could not constitute signatures and that the final email referred to a formal contract being produced which never materialised.

The Court of Appeal, however, agreed with the claimants and the High Court, confirming that the string of negotiated emails promptly signed, albeit even if informally, such as by first name, initials or nickname, would constitute an enforceable guarantee. The key was that the parties intended to be bound by the arrangement irrespective of the fact that the formal document which was expected to be drafted was never actually produced.

This judgment is, perhaps, not all that controversial, as it has long been established that contracts can be formed over email and through other means of instantaneous communication. However, what is clear from Golden Ocean is that if parties show intent to be legally bound to one another, they will be. Stating “Subject to Contract” on the top of all communications and draft documentation can be a useful way of clearly indicating that you do not want the content to be legally binding.

Looking ahead

It is increasingly clear that the law needs to adapt to keep up with the ever moving world of media and social networking. It is expected that the Parliamentary Joint Committee on Privacy Injunctions will recommend that social networks, such as Facebook and Twitter, be subject to injunctions and in doing so force sights to remove libelous comments. The same Committee may also request that Google censors search results in order to block such material from being accessed.

The ways in which businesses choose to communicate with each other are changing and as they do we need to look to see how the law applies to new forms of media. What Golden Ocean shows us is that laws that are centuries old can be applied to the media reality of today. Whilst the method may be different, the same rules can still apply – statements made through new media will be taken as seriously as those made by traditional forms.

Some advice

In conclusion here are three top tips to bear in mind when you are negotiating a legal arrangement:

1.Complete a formal agreement: if you do wish to formally document an arrangement then you should take it upon yourself to draft (or indeed have a suitably qualified lawyer draft) the appropriate agreement and not start trading with a counter-party until such agreement is finalised.

2.“Subject to Contract”: clearly write the term “subject to contract” on the top of all communications and draft documentation which you do not wish to be binding.

3.Don’t be fooled by modern media: do not be naive and think that by using email, Twitter, Facebook and various other forms of modern media that you are somehow out of the reach of the law.

Leathes Prior advise Football Club on successful conversion to a Community Interest Company

Leathes Prior’s Sports Team has continued to develop its expertise in assisting football clubs to survive in the difficult economic climate by advising Welling United of the Blue Square South division on its successful conversion to a Community Interest Company. See www.wellingunited.com for further details.

Full Contact’s Dan Chapman, assisted by Leathes Prior corporate lawyer Richard Guthrie, have advised Welling United throughout on their transfer from an unincorporated entity to a limited company which also has CIC status. Believed to be one of the first football clubs to have achieved such status, Welling may now become an example for other clubs to follow.

Richard Guthrie commented: “There is a growing trend for companies who have a real focus on supporting and being supported by their local community to seek CIC status, which is a relatively recent vehicle introduced in 2005 under the Companies (Audit, Investigation and Community Enterprise) Act 2004. Leathes Prior is able to advise companies in all sectors, sporting or otherwise, of the potential benefits of a conversion, taking into account other options such as CASC and charitable status”.

Dan Chapman added: “In an era where, quite rightly, more football clubs are considering passing some or all of their control to their fans, the community, supporters trusts and other such stakeholders it is vital that clubs take proper advice as to the best way to structure themselves. The CIC status was right for Welling United for a number of reasons, and we very much hope it is the start of a new era for this club which already does a lot for its local community. In a time when so many are commenting on the riches which are at play in the upper echelons of the football game, it is rewarding to be involved also in the real heartbeat of the game.”

One of the most notable features of a CIC is that it must operate at all times for the benefit of the community, and it is protected by an ‘asset lock’ which ensures (in the case of a football club) that decisions cannot ever be taken for private gain.

Complimentary room hire when you dine at Norwich City Football Club

We are delighted to announce that complimentary room hire will be offered to all customers looking to hold a three-course dinner with us at Norwich City Football Club*. Choose from one of our stylish function rooms for your next awards dinner, anniversary party or wedding and our experienced Event Co-ordinators will work with you to find a menu that’s right for you.

To take advantage of this fantastic offer call Canary Catering now on 01603 218704 or e-mail canary.catering@ncfc-canaries.co.uk.

*This offer excludes bookings taking place throughout the month of December and minimum numbers will apply.

Business Executive (CEO) Position Available

Due to expansion and emerging market opportunities CTS Ltd are looking for a dynamic business focussed individual to become CEO and to join the Directors and Management team. The role will include the implementation of the company’s strategic plan to complete business objectives and continue future growth.

The right candidate will receive salary and equity incentives in line with company targets. Please apply in writing with a current CV to

Gavin Springall company Director 1st Floor Phoenix House 3 White Lodge Business Park Hall Road, Norwich, Norfolk. NR4 6DG

Tel: 01603 610586 | Fax: 01603 612245 | E-mail: info@construction-training.comweb: www.construction-training.com