Official Report: Minutes of Evidence

The Chairperson (Ms Bunting): I welcome to the meeting Julie Wilson, who is the deputy director in the victims support division. Julie, you are welcome back. I welcome Emma Crozier, who is the head of violence against the person branch, and Leonie Gilmore, who is deputy principal in the violence against the person branch. Ladies, thank you very much. Apologies that we had to put you through all of that. It was quite tortuous, but we got there in the end. Thank you for your patience and forbearance. I invite you to give your presentation. I am sure that there will be some questions for you at the end, but, for now, the meeting is yours.

Ms Julie Wilson (Department of Justice): Thank you for the opportunity to brief you on work to develop a new seven-year domestic and sexual abuse strategy. It is intended to build on the previous strategy, which originally ran from 2016 to 2023. In the absence of Ministers, the final year 7 action plan was extended by way of an addendum. That strategy delivered a number of important developments, including the launch of the domestic violence and abuse disclosure scheme (DEVADS); the introduction of a new domestic abuse offence that covers not just physical violence but coercive control; the launch and roll-out of Operation Encompass to ensure that children who have experienced domestic abuse in their homes are supported in the school environment; the provision of new advocacy support services to those experiencing abuse; and the establishment of domestic homicide reviews to learn lessons so that we can enhance protections and, hopefully, prevent future deaths.

Despite that progress, domestic abuse alone still accounts for almost a fifth of police recorded crime, so I want to acknowledge up front that there is a lot more that we need to do collectively to tackle domestic and sexual abuse. The new draft strategy is intended to help us to do that. Whilst any strategy needs to be clear about the vision that it sets, it also needs to be more than mere words. This is intended to set the direction for the delivery of achievable, measurable and meaningful improvements. Running through each section of the strategy is an integrated performance framework that sets out the outcomes that we seek to deliver, indicators of what success looks like and what we will measure to see whether we are achieving what we are setting out to achieve.

Alongside the draft strategy, we have developed an initial three-year action plan. That is a change in approach since our last strategy, which was delivered through a series of annual action plans. Since delivery of many of the planned actions will span several years, we believe that a multi-year action plan is the best approach.

On its scope, the strategy is jointly led by the Department of Justice and the Department of Health, with input from other Departments, notably Education, Communities and the Executive Office. I want to touch for a moment particularly on the interdependencies with the Executive Office's strategy on ending violence against women and girls and on the alignment between the two strategies.

We believe that it is right that there are two separate strategies. They are distinct, and they seek to address different issues. On the one hand, you have domestic and sexual abuse, which can happen to anybody irrespective of their age, their race, their gender, their gender identity, their sexual orientation, their ethnicity or their background, and we need to respond to the breadth and the diversity of need there. On the other hand, you have a strategy that is looking at gender-specific violence against women and girls but is not limited to domestic and sexual offences. There are two strategies, but we cannot ignore the interdependencies. We know that women and girls are disproportionately affected by domestic and sexual abuse, so anything that we do to tackle it under our strategy will also deliver outcomes against the ending violence against women and girls strategy. Therefore, they are, ultimately, complementary and mutually reinforcing strategies, and we will continue to work collaboratively with the Executive Office to ensure that there is alignment and a joined-up response.

I said that anyone can be a victim of domestic and sexual abuse and that individuals can present with a number of different characteristics. Through the strategy, we want to progress work that will help us to understand intersectional needs better, and we want to carry out work that will help us to understand how best to respond to intergenerational abuse.

The strategy has five pillars: partnership, prevention, children and young people, support and provision, and justice. The partnership pillar is more than a pillar; it is — I will mix metaphors — a thread that runs through the entire strategy. We cannot do this alone. Domestic and sexual abuse affects the whole of society, so it needs a cross-sectoral and whole-society response. The strategy cuts across the work of multiple Departments and operational agencies, but I also acknowledge the role of voluntary and community sector partners in delivering services, sharing knowledge and expertise and communicating the voices and views of those with lived experience. The second pillar is prevention. Our focus in that regard is on making sure that people are informed and aware of different types of abuse, challenging attitudes and behaviours, and building capacity and capability in order to identify and respond to abuse earlier. The third pillar focuses on children and young people. We know that their experiences of domestic and sexual abuse can result in lifelong trauma, so we want to make sure that they feel confident to report abuse and can access services and support to help them to recover. Early intervention will be key, including an understanding of how to form healthy relationships. The fourth pillar is about ensuring that there is access to tailored support and provision. The fifth pillar is about ensuring that our justice responses are effective. That includes work to improve confidence in reporting abuse and on reducing barriers to participating in the justice system.

I will touch briefly on how we developed and informed the strategy. We launched a joint call for views with the Executive Office in January 2022. The responses from that identified issues and key themes that informed the development of the initial draft strategy, which we launched for public consultation in February 2023. We also held public engagement events online, and we met individual stakeholders bilaterally to discuss specific points. Throughout that process, we worked really closely with TEO to identify areas of shared interest and maintain alignment.

The engagement process confirmed broad support for the overall vision and outcomes, but it raised important issues that we have sought to address in the revised strategy, including greater clarity around governance and performance metrics to enable us to assess the strategy's impact and whether it is doing what we want it to do. There is also now a specific pillar on children and young people. The issue of funding was also raised, specifically the need for the strategy to be adequately funded. We have acknowledged that in the draft strategy. We will include delivery costs in action plans where those are known. However, as you will be aware, funding and affordability issues are likely to remain challenging and are likely to affect the scale and pace of delivery.

I hope that you found that brief overview helpful. We are happy to try to answer any questions that you might have.

The Chairperson (Ms Bunting): Do members have any questions?

Miss Hargey: Thanks very much for the update. The issue of funding for the action plan and the work going forward was raised in the paper. You touched on collaboration and alignment with the Departments. Budgets are being agreed at the moment in Departments. What work has been taking place around that? What can be delivered in the first two years of the action plan? Is there good cross-departmental work, or are there gaps in certain areas? Could we be more effective with the budgets that we have through better design?

You touched on the call for evidence and the work of the voluntary and community sector. Women's Aid has lost funding, which has had an impact. It would have been very much involved in the other strategies that you mentioned. What will the impact of that be on those organisations?

Will you give me a bit of an update on who is involved in the delivery board and oversight from across the Departments? What does that look like? Are there external partners, such as Women's Aid or other organisations, out there that are part of the board?

Ms Wilson: I will go with funding first, and you can remind me if I miss anything. We have very recently had our departmental budget confirmed. Some of the things that we deliver through the action plan in Justice are covered by our core budget. We have had confirmation that some of that is in place. Other Departments will be in a similar position, in which they will fund some of the measures that they have included in the strategy and action plan from their core budgets.

In addition, there is a cross-departmental budget, which has been confirmed as £1·621 million. We have had that confirmed. As an oversight board, we have not had an opportunity to look at the allocation of that funding, because it has literally just happened. We invited Departments to submit bids to the oversight board for what they would need from it.

Obviously, £1·62 million is not a huge amount. We will have to look at how we prioritise, which has been the position in the past few years. The strategy delivery board has taken decisions on funding allocation based on statutory and contractual commitments, on the impact on victims and on where we can make the biggest impact that is aligned with the strategic outcomes. We will take that approach again. We will then make recommendations to Ministers about the allocation of that funding.

Some things are covered by departmental budgets, and some things are covered by that £1·62 million, but we anticipate that it will be oversubscribed, and we will absolutely have to prioritise. That comes back to my point about the fact that the scale and pace of delivery will be impacted.

We will explore the options for other pockets of funding that we might be able to access at different times. Again, there are certainly uncertainties around future funding, but we will seek to explore options where we can.

Miss Hargey: Are you confident, however, that you can roll out a lot of the action plan, notwithstanding some of those challenges, or will you focus more on certain areas?

Ms Wilson: Certainly from a Justice perspective, there are some things in the action plan that we included and that, we said, we want to do, but those will rely on additional funding being found. There are some things that were already funded, some things that we do not have funding for and some things that will be subject to the board. We have made a bid for part of that £1·62 million. The conversations about how it gets divided up have not yet been had.

You asked about whether we work together effectively. We can always work more effectively together. As an oversight board, we have representation from each of the key Departments that feed into the strategy. Each Department is bidding for funding. We have worked really closely with the Departments to look at how the strategy is developed and how the different measures that particular Departments are responsible for can work together to reinforce the package of measures that the action plan and the strategy will deliver. As part of that, I mentioned that we have been working really closely with the Executive Office on its strategy and how that aligns with ours as well.

We can always do better. There are opportunities, particularly with the Executive Office, for us to work closely. It is understood that there are data gaps, and we need to look at how we gather data, but, rather than us all looking at how we do that, can we look at it collectively? There are opportunities for us to work collectively on individual pieces of work to realise where the synergies are. There will be differences. The Executive Office will want to look through the lens of women and girls, and we will want to gather other data that is not specific to women and girls, but there are opportunities to work more closely together.

You also asked about funding for the voluntary sector. We absolutely recognise the really important role that the voluntary sector plays. We understand that the Department of Health has found it necessary to discontinue a range of funding for the voluntary and community sector, including for the Women's Aid Federation. An Assembly question has been asked about that, and we responded to say that, as a Department, we are not in a position to pick up on that. Again, it is one of those things where we can look at the £1·62 million as a strategic oversight board, but we have not had that conversation yet: we have not looked at how that £1·62 million gets divided out, and I just know that it is going to be oversubscribed.

There are other areas where, as a Department, we are either grant funding or contracting services from the voluntary and community sector, so funding streams are going in that way. Furthermore, I understand that, through the assets recovery community scheme, the Women's Aid Federation for Northern Ireland has been allocated funding for very discrete project work. One of those is around the development of a forum for people with lived experience, so that we can engage and be informed by their experiences. It has also been allocated funds for training. It does not replace the funding that it lost, but it contributes to where there are some gaps.

Miss Hargey: Thank you very much.

Ms Wilson: Did I answer all your questions?

Miss Hargey: Yes, thank you.

Ms Ferguson: Over the last seven or eight years, obviously, the strategy has been critical and key actions have been delivered and will be ongoing in its revision.

Regarding the collaboration, have there been any short- or medium-term savings that can be reinvested into the outstanding actions? Obviously, it is welcome that your partner organisation is bringing additional money to enhance the actions in the strategy. However, there are actions outstanding, and budgets are tight, as we know. Has there been anything over the last seven years through that effective collaboration and cross-departmental working? Were there efficiencies through which you were able to redirect resources into fulfilling additional actions? Or is that something that you look at more?

Ms Wilson: Certainly, there has been some redirecting of resources. It has not always been through efficiencies; sometimes it has been through not being able to spend on one thing because there may have been a recurring tail of cost. We have been working on a year-by-year basis, and, where there would be recurring costs from the introduction of something, we have not always been able to introduce it, because that future funding has not been guaranteed. There have been some things, such as the introduction of children's sexual offences legal advisers (SOLAs), that we have not been able to do yet, because of that future funding piece. In those cases, funding like that has been redirected.

I am trying to think of examples of where we have been able to do something else. I do not have any examples in front of me, and I cannot think of them off the top of my head. I do not want to ad lib, in case I get it wrong.

Ms Ferguson: I appreciate that. I know that seven years is quite short in the development of a strategy, getting it up and running, having clear actions and trying to monitor and evaluate. I appreciate that, but my point is that, in doing that effective collaboration work, you need to start to see the cost efficiencies that have been built in. That means improvements through cost efficiencies: with the same amount of money, you can redirect resources into the additional new services that are not being able to proceed because you have a baseline amount of funding and are constantly reliant then on monitoring rounds and so on. It will be interesting to see, maybe in the next five or six years, where that added value goes and how, with the efficiency in the Department and all the organisations, you can improve the service. Thank you.

The Chairperson (Ms Bunting): Stewart, do you have anything to ask?

Mr Dickson: Deirdre asked the questions that I was going to ask about interdepartmental working and the budget, and the answers have been helpful. Thank you.

The Chairperson (Ms Bunting): Go ahead, Justin.

Mr McNulty: Why have reports that are required to be laid within two years of the commencement of sections 29 and 34 of the Domestic Abuse and Civil Proceedings Act (NI) 2021 not been laid? Is work under way to deliver those, and how does their not being laid impact on the overall delivery of the strategy for victims?

Ms Wilson: Sorry, are you referring to the reports on the operation of the Act or on domestic abuse protection orders and notices?

Mr McNulty: I was referring to the Domestic Abuse and Civil Proceedings Act.

Ms Wilson: I think that this is about the Criminal Justice Inspection Northern Ireland (CJINI) reports and the report on training. Do you want to talk about those, Emma?

Ms Emma Crozier (Department of Justice): Sure. Is it the reporting requirements that we are referring to? Yes.

A lot of reporting requirements are set out in the 2021 Act, as you said. One of those was for us to appoint an independent body to review the implementation of the 2021 Act. We appointed CJINI, which published a report last month on the operation of the 2021 Act. Overall, it was positive. The three recommendations for the Department of Justice referred to ensuring that we promote our statutory guidance and e-learning. CJINI agreed that those were positive bits of work but that it was about promoting them more widely. We will take that forward.

CJINI is one part of that. We are also working with our statisticians across the criminal justice organisations, and we will produce a report on numbers of domestic abuse offences from police statistics through to prosecutions and convictions. The other thing is that we are required to produce an annual training statement. Our last one was produced in August 2023, and we will produce another one and publish that on the website in August this year. Those are most of our requirements under the 2021 Act.

Mr McNulty: OK. Why were reports not delivered within the time frame?

Ms Crozier: The only one that we have not yet laid is the training statement.

Ms Wilson: They have been laid within the time frame. The one thing under the 2021 Act that has not been laid within the time frame was a requirement to bring forward regulations for domestic abuse protection orders and notices. We previously provided a written briefing to the Committee outlining that, as we have been taking forward that work, we have identified issues that we need to look at more closely. There are operational issues and issues with the volume of notices that would be generated by the current form of the legislation.

We also have concerns not just about cost but about the added value that those notices would bring. Our assessment is that they would be expensive but would not meaningfully enhance protections for victims of domestic abuse beyond what is already available through other measures. We are considering that further. The Minister is also considering how we ought to proceed, and we are looking at options. That is the only thing under the 2021 Act that we have not done within the time frame. That was not a reporting requirement, however; it was a requirement to lay regulations before the Assembly.

Mr McNulty: Thank you very much.

The Chairperson (Ms Bunting): May I come in on that one, Julie? I understand that you have identified issues, and it might be helpful to get an update on what some of those are. You have outlined some of them, but it would be good to get the detail. I appreciate that this came from our predecessor Committee, but the issue around the value of those notices and all the rest of it is that, after a debate in the House, the Assembly made a decision that the Department was to do that. It is not for the Department to say that it will not do that; it is the law now. We would like to have an update on that because, clearly, the House felt that that work was of sufficient value and merit to be taken forward. Maybe, at some stage, you will give us an update on that, please.

Ms Wilson: I can touch on some of the issues now, if you like. The legislation would require the police to make a domestic abuse protection notice where there is risk of harm from domestic abuse. It has been a complex process to look at how many of those notices would be issued in a year and the associated costs of that. There has been a lot of looking at the impact of the volume of cases. Flowing from that, the likely costs for the police in the first year of introduction would be £12 million, rising to £17 million.

Some of the issues associated with that are around the time frame. If a police officer responds to a call, particularly in the middle of the night, and decides that they need to issue a protection notice, there needs to be a compressed time frame for that to be brought to the court for an application for a domestic abuse protection order. The operational arrangements to do that, particularly where it occurs in the middle of the night, which is when most of those calls will be, are not there to support it. They would need new processes to be in place to support that.

The Chairperson (Ms Bunting): For the police or for the courts?

Ms Wilson: The courts and police would both need to have new processes. However, cutting through all that, aside from the affordability issues around the sheer amount that it would cost, the restrictions that a protection notice could place on an individual mirror what is already available under police bail conditions. Protection notices would not add to or enhance the available protections in any way. We had looked at whether it was possible to include positive requirements, such as a requirement to do, for example, a behavioural change programme or a substance misuse programme, but, at this point, the availability of those programmes could not be guaranteed. They are not in place in that volume, and the system's capacity to deliver them is not there. Therefore, they have not been included in the current draft regulations. As a result, the protections that would be available under a domestic abuse protection notice or order would be the same as what is currently available under police bail. The system would be hugely resource-intensive. Our assessment is that supporting delivery of the system, given the huge volume of cases. would potentially deflect police from other policing priorities without being able to deliver anything additional.

We are trying to work through those issues. We are looking at things like the threshold for when a domestic abuse protection notice would be triggered to see what changing that would do to the volume of cases. If it is currently set at "risk of harm", should it be set at "risk of serious harm"? Those are the kinds of considerations that we are trying to work through at this point, but we have not got there yet.

The Chairperson (Ms Bunting): We would all appreciate it if you would keep us updated on that. There is some consternation about circumstances in which the Assembly has passed law and, not for the first time, those who are supposed to implement it determine which aspects they will implement and which they will not and what should be prioritised and what should not, even though the Assembly has voted on it. Certainly, that happened with the Human Trafficking and Exploitation (Criminal Justice and Support for Victims) Act (Northern Ireland) 2015, and we now see it with the Domestic Abuse and Civil Proceedings Act (Northern Ireland) 2021. All those issues, I suspect, were thoroughly debated in this room and on the Floor of the House. I understand the resourcing issues at present. However, I am concerned about the general principle that the police and Department decide that they will prioritise this and will not prioritise that, regardless of what the House has said and how it voted.

That is fair enough. If you keep us updated, that would be helpful.

I have a couple of other things. I am working through your paper, which is useful. I have spoken to you before on the intersectionality issue. I understand the need to tailor services to people's needs. My query on that is this: how do you tailor to people's needs when, once you get into the arena of intersectionality, there is grave potential to create a hierarchy of victims? To my mind, anybody who is faced with those circumstances is having an awful time. Is it worse for some than for others? I am not sure that it is. How do we balance your proposal of intersectionality with not creating a hierarchy of victims?

The next issue is Operation Encompass. I know that you intend to roll that out. Operation Encompass is a great thing. However, the PSNI had to absorb the funding for that. If you are to roll it out further, across nursery schools and so on, to which I have no objection, will the PSNI receive additional funding for that?

There are elements of relationships and sexuality education (RSE) that are controversial, as you will appreciate. It is a difficult space for schools, parents, guardians, teachers and governors — all of them — because we need children to have an understanding, but it needs to be at an appropriate level. Who determines what is appropriate and what everybody's roles are in all that? I note that, in your proposals, there is a lot of querying of teachers whether they are well enough equipped, have what they need and all those things. What I do not see is how you will consult parents on whether things are working for them and how they deem things to be working for their children.

There is mention in our papers of a DASS pilot. I do not know what that is.

Finally, with regard to prioritisation, this strategy is, I suppose, led by Health and Justice, with, I think, Education, Communities and the Executive Office also participating. How are work and money prioritised? Does each Department prioritise in its own area? Do the leads agree what the priorities will be? Does each prioritise within its own remit and money? How will that work in prioritising the issues in the strategy and finding the money to take it forward?

Ms Wilson: I will answer that last question first. It is a little of both. Departmental inputs have been led by Departments. Where there is something for Health or Education to deliver and it falls entirely within the remit of one of those Departments, it has identified what its priorities are in its response to domestic and sexual abuse and how it contributes to the strategy. Some of what Departments identified will be met by their departmental core budget. That is where they prioritise. Where we have come together collectively is on the shared budget and what is met out of that. As an oversight board, we have asked Departments for bids, and we will consider those bids and how they align with the strategic objectives under the strategy and the action plan. We will then make recommendations to Ministers on how that funding should be allocated.

As I said, the funding will be oversubscribed. We will take other opportunities, if they arise, to bid for additional funding, but we operate on the basis that we have a relatively small cross-departmental budget and are also prioritising things within our own core budget. Some of the things that we meet from within our departmental budget include, for example, funding for behavioural change programmes within the Probation Board for Northern Ireland (PBNI). Likewise, the Department for Communities funds Women's Aid refuges from its departmental budget rather than from that shared pot. There is a little of both: each Department prioritising within its own budget but also collectively agreeing how that £1·62 million can be allocated between us.

On the intersectionality question, we absolutely agree that there should not be a hierarchy of victims. Where intersectionality comes into its own is that victims will present with different needs. We have an advocacy service that is intended to provide support to any victim but also to identify their needs and, maybe, refer them on to other services. The approach of the advocacy service is to look at high risk and high harm, so there needs to be a proportionate response to every victim's needs. Any victim facing these offences faces an appalling experience and needs that support. The reality is that our resources are limited, so they need to be targeted at where the need is greatest.

The approach in our advocacy service or the services that we fund has been that these services are available to all. There may be additional needs that require people to be referred to other services. I accept that there are often waiting lists for those services because of resourcing constraints.

We are trying to understand more about people's needs and how they are impacted by their experiences — who they are, what their lives are like and what challenges they face — and to understand where there are gaps in the system. However, it is also about ensuring that there is a service that is available to anyone but that will be proportionate to the harm and risk that they are experiencing, simply because we have to tailor our resources to and target them at that high harm and high risk.

The Chairperson (Ms Bunting): Thank you.

Ms Wilson: You had asked about RSE as well.

The Chairperson (Ms Bunting): Yes, I asked about RSE and Operation Encompass funding for the police. I also asked what the DASS pilot was.

Ms Wilson: On RSE, the education input to the strategy has come from the Department of Education and has been agreed with its Minister. I am not sighted on what it is doing to engage with parents.

It is, however, very much focused on informing, empowering and enabling not only professionals but families and carers who work with children to identify and respond to risk. That forms part of that wider package for children and young people. Its aim is prevention, where possible, including through providing an understanding about healthy relationships.

I appreciate that some of that is contentious and that there needs to be consultation with parents, but it is not just about that. It is about empowering the people around children and young people to recognise and respond to risk; it is about making sure that, where a child is exposed to abuse, supports are in place and are accessible; and it is about providing access to justice, improving confidence in justice and removing the barriers for children and young people in the justice system so that they can get justice and perpetrators can be held to account. Education is absolutely a part of that. It is only a part, however, and all of the pieces need to come together: prevention and protection but also support and justice when something happens.

The Chairperson (Ms Bunting): Another question occurred to me when you were speaking. What happens in the circumstance that the Department of Justice prioritises its actions but some of the other Departments say, "We don't have the money. What can we do?". What happens then? You might have prioritised it, but, if other people do not put their shoulder to the wheel, where does that leave the strategy?

Ms Wilson: The strategy as a whole has been informed by Departments collaborating and by our engagement with the voluntary and community sector and people with lived experience. All the departmental inputs provided have been agreed with the respective Minister with the exception of Health, because of the change of Minister. The new Minister of Health has not had an opportunity to consider this. It is still very much a draft strategy, and that agreement will need to be secured. Departments have committed to the measures in the draft strategy and agreed them with their Minister. I assume, on that basis, that they will prioritise those.

The Chairperson (Ms Bunting): You are hopeful at this stage. We will take that as read.

You were going to speak to me about the DASS pilot and the funding for PSNI for Operation Encompass.

I have one further question. I have no doubt that the majority of people who are in these circumstances are absolutely genuine and are having a horrendous time. However, I am long enough in the tooth to know that there are cynical people who do the innocent, genuine victims a great disservice by claiming to be experiencing some of these issues in a bid to improve their contact arrangements and financial settlements around divorce and so on. It is horrible that it happens, but we should be mindful of the fact that it does. How will you monitor the extent to which some elements in the strategy could be exploited to the detriment of genuine victims or defendants who have been wrongly accused?

Ms Wilson: Ultimately, the criminal justice side will be a matter for the courts. The behaviours that constitute domestic abuse are set out in the domestic abuse offence. Other offences could be brought to bear with a domestic abuse aggravator. That is a matter for the courts and will be based on the evidence presented to them. In family courts, a range of work is being progressed. For example, the Victims of Crime Commissioner has indicated that she wants to take forward research about family courts from the perspective of children. There will be a lot of learning from that that we will want to consider when the research is done. I do not lead on family courts, so I do not want to stray too far. Those are not the issues that I am most familiar with, but I know that work is ongoing around family courts and the points that you made. We are alive to those issues, as they have been raised with us.

On criminal justice, the offence sets out the behaviours, and the courts will determine on the basis of the evidence whether that offence has been committed. Ultimately, it is right that it is for the courts to do that.

Emma, do you want to say anything about the DASS pilot?

Ms Crozier: Yes. That is a Department of Health lead. I believe that it is support for victims in trust areas and in hospitals, but we can get more information from our Health colleagues on that pilot and send it through.

Ms Wilson: The roll-out of Operation Encompass is in our action plan. The costs beside it are to be confirmed (TBC), but I know from speaking with police that the TBC costs will not be insignificant. It is one of the measures that will need additional funding for it to be rolled out. That is an area where the scale and pace of delivery are really impacted by available resources.

The Chairperson (Ms Bunting): That is fair enough, thank you.

Does anybody else have anything? OK.

Ladies, thank you very much for your time. We really appreciate it.