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September 22, 2014
It is intended for reference purposes only and does not constitute definitive advice. Links to the original source materials are included where there are no restrictions in terms of access. References may also be made to sources that require separate registration or subscription. A link to a source does not necessarily imply endorsement of the source or the material provided through the link. For further information on any of the matters discussed in this summary please contact Alexander Ross. If you have any comments, queries or suggestions please contact us at comments. All suggestions and comments are most welcome.
Supreme Court rules that agent holds proceeds of bribe or secret commission on trust for his principal.
Court of Appeal rules money paid under illegal agreement for insider dealing is recoverable where performance of contract was frustrated.
International Telecommunication Union, United Nations Children’s Fund, and partners of Child Online Protection Initiative release updated Guidelines to strengthen online protection for children.
Article 29 Data Protection Working Party publishes statement welcoming Court of Justice of European Union’s judgment that the Data Retention Directive (2006/24/EC) is invalid.
Information Commissioner’s Office survey finds 85% of mobile apps fail to provide basic privacy information.
New Independent Press Standards Organisation begins work.
European Court of Justice finds that Member States may authorise libraries to digitise books in their collection to make them available at electronic reading points without consent of rights holders.
Press Complaints Commission publishes its final adjudication before closure.
Media Standards Trust publishes analysis of UK national newspaper coverage of press regulation following Leveson Report.
Professional Publishers Association encourages press publishers to join IPSO.
Ofcom upholds appeal against ATVOD Determination that adult service “The Urban Chick Supremacy Cell” was an on-demand programme service (ODPS).
European Commission approves acquisition of Sky Deutschland and Sky Italia by BSkyB.
ATVOD rules that 74 UK websites failed to protect children from online pornography.
European Commission consults on cross-border mergers and divisions.
Gambling Commission reminds offshore operators of imminent deadline to apply for licences to provide services to UK consumers once Gambling (Licensing and Advertising) Act comes into force.
UK Interactive Entertainment Association outlines policy manifesto to take UK games sector to the next level.
Supreme Court rules that agent holds proceeds of bribe or secret commission on trust for his principal.
Cedar Capital Partners acted as the claimants’ agent in the purchase of the Monte Carlo Grand Hotel for €211.5m. At first instance, the judge found that Cedar had not made proper disclosure that it was to receive a commission fee of €10 million. The judge made a declaration of liability against it for breach of fiduciary duty and ordered it to pay that sum to the claimants. However, he declined to grant the claimants a proprietary remedy. On the claimants’ appeal, the Court of Appeal overruled the judge and held that Cedar had received the €10 million fee on constructive trust for the claimants.
On cedar’s appeal, the question before the Supreme Court was whether a bribe or secret commission received by an agent is held by the agent on trust for his principal, or whether the principal merely has a claim for equitable compensation in a sum equal to the value of the bribe or commission. This was of practical significance for two reasons. First, if the bribe or commission was held on trust, the principal had a proprietary claim to it, which on the agent’s insolvency would give the principal priority over the agent’s unsecured creditors, whereas otherwise he would rank equally with such creditors. Secondly, if the principal had a proprietary claim, he could trace and follow it in equity, whereas a principal with a right only to equitable compensation would have no such equitable right to trace and follow.
Cedar argued that no proprietary claim arose because the bribe or commission was not a benefit that could properly be said to be the property of the principal. The claimants argued that, in any case, where an agent receives a benefit which is, or results from, a breach of the fiduciary duty owed to his principal, the agent holds the benefit on trust for the principal.
The issue had produced inconsistent judicial decisions over the past 200 years, the court found. It was not, therefore, possible to identify any plainly right or plainly wrong answer. Nonetheless Lord Neuberger, giving the judgment of the court, preferred the claimants’ position, which was consistent with the fundamental principles of agency law. It also had the merit of simplicity and was supported by wider policy considerations. In particular, secret commissions undermined trust in the commercial world and the law had to be particularly stringent in relation to a claim against an agent who had received a bribe or secret commission. Lord Neuberger considered it just that a principal whose agent had obtained a bribe or secret commission should be able to trace the proceeds of the bribe or commission into other assets and to follow them into the hands of knowing recipients (FHR European Ventures LLP v Cedar Capital Partners LLC [2014] UKSC 45 (16 July 2014) – to read the judgment in full, click here).
Court of Appeal rules money paid under illegal agreement for insider dealing recoverable where performance of contract was frustrated.
The claimant, Chandrakant Patel, entered into a deal with the defendant Salman Mirza involving the use of Mr Mirza’s spread betting account with IG Index to bet on the movement of RBS shares, the attraction being that Mr Mirza had access to insider information. Mr Patel transferred £620,000 to Mr Mirza’s bank account. When information failed to materialise, Mr Patel wanted his money back but Mr Mirza said he could not return it because it had been mistakenly transferred to a third party.
Mr Patel issued proceedings. He claimed that the consideration for the payment of the money had wholly failed, that in receiving and failing to repay it, Mr Mirza had been unjustly enriched. At first instance the judge held that Mr Patel’s claim was barred by illegality.
On appeal, Lord Justice Rimer held that Mr Patel was not so barred and that he was entitled to recover the money even though he had not withdrawn from the agreement before its implementation had become frustrated. Mr Patel’s case ran straight into the principle of public policy that “the courts will not lend their aid to claimants whose case is stated to be, and is, reliant on illegality” (Holman v Johnson (1775) 1 Cowp 341). Nevertheless, the authorities clearly showed that, if before he had learnt that his venture with Mr Mirza could not be carried out because none of the expected insider information would be forthcoming, Mr Patel had repudiated and withdrawn from the agreement, he would have been entitled to sue for and recover his £620,000 even though in order to do so he would have had to plead the illegal arrangement under which he had paid it over (see Taylor v Bowers (1876) 1 QBD 291). In Rimer LJ’s view, it did not make any difference if the claimant’s withdrawal from the illegal agreement was not because of a change of mind that he no longer wished to participate in it, but was because the agreement was no longer capable of being performed at all. In such circumstances, Rimer LJ considered that it was equally open to Mr Patel to rely on the wholly unperformed illegal agreement and to be entitled to recover his money (Chandrakant Patel v Salman Mirza [2014] EWCA Civ 1047 (29 July 2014) – to read the judgment in full, click here).
International Telecommunication Union, United Nations Children’s Fund, and partners of Child Online Protection Initiative release updated Guidelines to strengthen online protection for children.
The “Guidelines for Industry on Child Online Protection” provide advice on how the ICT industry can help promote safety for children using the internet or any technologies or devices that can connect to it, as well as guidance on how to enable responsible digital citizenship, learning and civic participation. The updated version provides guidance specifically aimed at companies that develop, provide or make use of information and communication technologies.
The Guidelines call for a comprehensive response to the online risks facing children and partnerships across multiple stakeholder groups, including governments, companies, civil society, parents and educators.
Simon Milner, Policy Director, Facebook said: “Children’s online safety is a responsibility we all share: from those who care for and teach children, to the companies who provide online services, to policy-makers. Our goal at Facebook is to provide the most accessible online tools for teens as well as to enable them to seek help and advice when they need it. The Guidelines provide a framework for company action on children’s online safety, so we appreciated the opportunity to contribute our expertise to their development. They are practical, evidence-based and should be impactful“.
The Guidelines were developed in alignment with the UN Guiding Principles on Business and Human Rights and the Children’s Rights and Business Principles. To read the press release in full and for a link to the updated Guidelines, click here.
Article 29 Data Protection Working Party publishes statement welcoming Court of Justice of European Union’s judgment that the Data Retention Directive (2006/24/EC) is invalid.
In the statement, the Working Party urges EU Member States and EU institutions to consider the consequences of the ruling, which the Working Party says sets “a new standard for national data retention legislations“.
In Cases C-293/12 and C-594/12 Digital Rights Ireland v Minister for Communications, Marine and Natural Resources the CJEU found that the Directive:
- amounted to a wide-ranging and particularly serious interference with the fundamental rights to privacy and to the protection of personal data;
- failed to circumscribe such interference to ensure that it was limited to what is strictly necessary for the purpose of fighting “serious crime”, thereby leaving it too open for Member States to decide on the scope of data retention; and
- failed to define any guarantees concerning data retention, i.e. there were no criteria to determine retention periods, nor were there any appropriate technical and security measures and conditions governing access to and use of data by national authorities.
The CJEU’s decision was also motivated by the fact that the Directive did not require that data be retained within the EU. Consequently, it did not ensure compliance with the requirements of protection and security by an independent authority, which is explicitly required by the Charter and is “an essential component of the protection of individuals with regards to the processing of personal data“.
As such, national measures based on the invalidated Directive are not directly affected by the ruling. However, the Working Party urges Member States as well as European institutions to evaluate its effects on national data retention laws and practices in the EU. Indeed, national legislation has to comply with Article 15(1) of the e-Privacy Directive (2002/58/EC), which sets out rules for retaining electronic communications data. Such legislation clearly falls within the scope of EU law and is therefore in compliance with the Charter and the general principles of EU law as interpreted by the CJEU.
In particular, national data retention laws and practices should ensure that there is no bulk retention of data in general and that, instead, data are subject to appropriate differentiation, limitation or exception. Also, access and use by national authorities should be limited to what is strictly necessary in terms of categories of data and persons concerned. It should also be subject to substantive and procedural conditions. Moreover, the Working Party says, national laws should provide for effective protection against the risk of unlawful access and any other abuse.
The Working Party also calls on the European Commission to provide, without further delay, clear guidance on the consequences of the CJEU’s judgment, both at European and Member State level. To read the Working Party’s statement in full, click here.
Information Commissioner’s Office survey finds 85% of mobile apps fail to provide basic privacy information.
A survey of over 1,200 mobile apps by 26 privacy regulators from across the world has shown that a high number of apps are accessing large amounts of personal information without adequately explaining to those concerned how their information is being used.
The survey by the Global Privacy Enforcement Network examined the privacy information provided by 1,211 mobile apps. As a member of GPEN, the ICO examined 50 of the top apps released by UK developers.
The key findings are:
- 85% of the apps surveyed failed to clearly explain how they were collecting, using and disclosing personal information;
- more than half (59%) of the apps left users struggling to find basic privacy information;
- almost one in three apps appeared to request an excessive number of permissions to access additional personal information; and
- 43% of the apps failed to tailor privacy communications to the small screen, either by providing information in too small a print or by hiding the information in lengthy privacy policies that required scrolling or clicking through multiple pages.
The research did find some examples of good practice, with some apps providing a basic explanation of how personal information is being used, including links to more detailed information if the individual wants to know more. The regulators were also impressed by the use of just-in-time notifications on certain apps that informed users of the potential collection, or use, of personal data as it was about to happen.
Last year the ICO published “Privacy in Mobile Apps” guidance to help app developers in the UK handle people’s information correctly and meet the requirements under the Data Protection Act 1998. The guidance includes advice on informing people of how their information will be used. Research carried out last year to support the guidance’s launch showed that 49% of app users had decided not to download an app due to privacy concerns. To read the ICO’s press release in full and for a link to the full survey results, click here.
New Independent Press Standards Organisation begins work.
As of 8 September the independent Press Standards Organisation took up its role as press regulator. The new regulator will oversee editorial standards for the majority of national, regional, local and trade publications.
According to IPSO’s press release, the regulator will be “rigorous, independent, fair and transparent“. Subscribing publications will be expected to deal “fairly and swiftly” with complaints from their readers, with IPSO available to support members of the public who feel that their concerns are not being addressed properly. IPSO will monitor the complaints handling procedures of its subscribing publications with expectations of “clarity, efficiency, fairness and transparency“.
Chairman Sir Alan Moses said: “IPSO aims to help rebuild public trust in the press through independent, fair and transparent regulation. Its role as an independent regulator is to provide support and redress for victims of press abuse. To raise standards is to protect the public from abuse. The Board and I believe that the freedom of the press can best be maintained by supporting and enhancing standards through an independent regulator. To achieve that aim we are committed to establishing and demonstrating our independence. Where standards have been breached we will apply sanctions and seek redress. Where we see patterns of poor behaviour we will pursue change. Democracy depends on a free but fair press. Through independent regulation IPSO will make an important contribution to that vital objective“.
New complaints will be dealt with internally by the newspaper concerned. However, IPSO says that it will assist the complainant throughout the initial process. If the matter is not resolved satisfactorily IPSO will take the matter up. That said, IPSO says that complainants are “welcome to contact IPSO at any time if you are not sure how to proceed or need advice on how to frame your complaint“. IPSO will continue with complaints and investigations that it has inherited from the PCC. To read IPSO’s press release in full, click here.
European Court of Justice finds that Member States may authorise libraries to digitise books in their collection to make them available at electronic reading points without consent of rights holders.
The Technical University of Darmstadt in Germany digitised a book published by German publishing house, Eugen Ulmer KG, in order to make it available at its electronic reading posts. Eugen Ulmer issued proceedings in the German courts seeking to prevent the university from digitising the book in question and to prevent library users from being able, via electronic reading points, to print out the book or store it on a USB stick, and/or to take those reproductions out of the library. The German courts asked the CJEU to clarify the scope of the exception under the Copyright Directive (2001/29/EC) that allows publically accessible libraries to make works from their collections available to users via electronic terminals for the purpose of research or private study.
The CJEU held that, even if the rights holder grants a library the right to license his/her works on appropriate terms, the library may still avail itself of the exception under the Directive otherwise the library could not achieve its primary objective of promoting research and private study.
Further, the CJEU found that the Directive did not prevent Member States from granting libraries the right to digitise books from their collections and to make those works available to library users via electronic terminals if it was necessary to promote research or private study. The right of libraries to communicate to the public works in their collections would risk being rendered meaningless or ineffective if libraries did not also have an ancillary right to digitise the works in question, the CJEU said. Further, in this case, an ancillary digitisation right did not conflict with the normal exploitation of the work and did not unreasonably prejudice the legitimate interests of the rights holder given that German legislation provided that the number of copies of each work available on electronic terminals must not be greater than that which the library had already acquired in analogue format.
However, the CJEU held that a publicly accessible library’s right of communication did not extend to allowing individuals to print out the works on paper or to store them on a USB stick, as such acts constituted acts of reproduction resulting in new copies being made available to individuals. Such acts of reproduction were not necessary in order to exercise the right to communicate the work to the public and were therefore not covered by the exception under the Directive, particularly since the copies were made by individuals and not by the library.
The CJEU nevertheless added that Member States may, within the limits and conditions set by the Directive, provide for, in their national legislation, an exception or limitation to the exclusive right of reproduction of rights holders and thereby permit the users of a library to print the works out on paper or store them on a USB stick from electronic terminals. However, in those circumstances fair compensation must be paid to the rights holders. (Case C-117/13 Technische Universität Darmstadt v Eugen Ulmer KG (11 September 2014) to access the judgment in full, go to the curia search form, type in the case number and follow the link).
Press Complaints Commission publishes its final adjudication before closure.
A woman complained to the PCC that an article published on the website of Best magazine, Bestdaily.co.uk, on 14 May 2014 identified her as a relative of a person convicted of crime in breach of Clause 9 (Reporting of Crime) of the Editors’ Code of Practice. She was further concerned that the article was misleading in breach of Clause 1 (Accuracy) of the Code.
The article reported that the complainant’s husband had been found guilty of eight charges of inciting children to engage in sexual activity and two charges of making indecent images of children. It identified the complainant as his wife, naming her and giving details of her profession and education.
The complainant said that she was entirely irrelevant to the defendant’s crime and, contrary to the article’s implication, had been separated from him for over a year. While the fact of their marriage was of potential relevance, particularly as the material had been found at the marital home, this could have been reported without identifying her, she said. Further, she had not been mentioned in court and had played no part in the proceedings. There was no public interest in identifying her.
The PCC found that, under the terms of Clause 9 of the Editors’ Code, the publication should not have identified the complainant in its online article unless she was “genuinely relevant” to her husband’s conviction. Although it was accepted by both parties that the defendant’s marital status was of potential relevance to his crimes, the complainant herself was of no genuine relevance; her identification was not therefore justified.
The article therefore raised a clear breach of the Code, which could have been avoided had the publication taken active steps to ascertain whether the complainant had consented to her identification in this context before publication, as required by the Code.
The complainant was further concerned that the article had not made clear that the couple were separated. This was a point of significance, particularly in the context of the defendant’s crimes and the potential effect on the complainant of being named as his wife. While the PCC accepted that the publication had swiftly corrected the article when made aware of the position, no evidence had been provided to suggest that it had made inquiries on this issue before publication. This constituted a failure to take care over the accuracy of the article, and amounted to a breach of Clause 1. To read PCC Adjudication on A Woman v Best (11 September 2014) in full, click here.
Media Standards Trust publishes analysis of UK national newspaper coverage of press regulation following Leveson Report.
The analysis found that:
- newspapers published an average of six articles about press regulation every day, over 2,000 in total;
- coverage, including news reports, was highly opinionated: over two-thirds of all articles expressed a view;
- opinions expressed were overwhelmingly negative: 60% of articles containing only negative opinions;
- more than 80% of leaders and comment pieces contained not one single positive comment; and
- public opinion about press regulation, as reflected in 24 opinion polls conducted during and after Leveson, was not represented by the national press.
The analysis included all 2,047 articles published in print and online by 19 national newspapers about press regulation in the 12-month period from 29 November 2012 (the day of publication of the Leveson Report) to 29 November 2013 (a month after the sealing of the Royal Charter). To read the MST’s press release in full and for a summary of the results of the analysis, click here.
Professional Publishers Association encourages press publishers to join IPSO.
The PPA is encouraging publishers that produce editorial content to join the new press regulator, IPSO. The PPA says that, in the event of receiving a complaint IPSO provides “a clear route to settle such complaints“. The PPA says that members of IPSO have an “insurance position” to be able to deal with and resolve any complaints effectively.
The PPA is also encouraging publishers to join as “this sends a strong and clear message to the Government that the press are united behind self-regulation“. According to the PPA, an independent regulator which covers a wide range of publishers including national newspapers, regional newspapers and magazines in all their forms, sends the strongest possible message to the Government that the industry stands united in favour of a free press and against state regulation of the media.
The PPA explains that publishers that are not members of IPSO will be outside the system of press regulation, meaning that they will have to resolve all complaints about their publications directly and may be more exposed to legal action and long, drawn-out complaints. Joining IPSO provides both complainants and publishers with an independent route to settle complaints, the PPA says.
The PPA reminds publishers that IPSO is also able to offer advice and guidance to publishers, which can include pre-publication advice about information publishers may wish to publish and advice on the conduct of journalists.
In addition, the PPA says, the Editors’ Code of Practice is not a public document that can be used without consent by publishers or others. It is subject to the law of copyright, and any publisher who has not signed the IPSO contract, but who is seeking to rely on the Code after 8 September 2014, must seek the prior permission of the Regulatory Funding Company (the funding body for IPSO). This is particularly the case if the Code has been expressly or implicitly incorporated into journalists’ contracts of employment or if it forms part of the publisher’s complaints handling processes. To read the PPA’s press release in full, click here.
Ofcom upholds appeal against ATVOD Determination that adult service “The Urban Chick Supremacy Cell” was an on-demand programme service (ODPS).
Ofcom has overturned ATVOD’s Determination and found that the adult service was not an ODPS and did not, therefore, fall within the scope of video-on-demand regulation.
Whilst the service did have as its principal purpose the provision of audiovisual material, Ofcom found that the material was not “TV like”. Although the short duration of the videos was not inconsistent with adult content linear programming, in Ofcom’s view “Urban Chick” was not a service that was likely to compete for the same audience as linear TV broadcasts. There were no titles or credits and the majority of the videos were neither self-contained or episodes from a wider series. Instead, they took the form of individual acts edited from longer, single fetish “sessions”. Further, there were no scripts and the narrative of many of the videos was also not typical of programmes comparable to those on linear TV.
In addition, Ofcom found, the videos were made with a limited production budget. Most were filmed in one location and many appeared unscripted. Further, audio had not been recorded using professional equipment and there was no accompanying music. Moreover, the videos were not professionally lit and the content appeared to have been filmed using basic, consumer-grade cameras. The production values of the service were therefore not closely comparable to professional content broadcast on linear services. To read Ofcom’s decision in full, click here.
European Commission approves acquisition of Sky Deutschland and Sky Italia by BSkyB.
The European Commission has authorised under the EU Merger Regulation the proposed acquisition of Sky Deutschland AG and Sky Italia Srl by BSkyB. All three companies are media companies, active primarily in the pay TV sector. Sky Deutschland and Sky Italia are currently owned by 21st Century Fox of the US. The Commission concluded that the transaction would not raise competition concerns, since the activities of the three companies are geographically complementary.
The Commission’s investigation showed that the geographic scope of the markets for the licensing or acquisition of audiovisual programming, the wholesale supply of TV channels and the retail of audiovisual programming to consumers, all for free to air and for pay TV, as well as the sale of TV advertising airtime, was national or in linguistically homogeneous areas. The Commission found that the transaction would not lead to any material overlaps in the parties’ activities, as they were mainly active in different national markets. BSkyB’s activities were mainly focused in the UK and Ireland, Sky Deutschland’s activities were mainly focused in Germany and Austria and Sky Italia’s activities were mainly focused in Italy, the Commission found. To read the Commission’s press release in full, click here.
ATVOD rules that 74 UK websites failed to protect children from online pornography.
ATVOD has published Determinations finding that two “adult” services, operating across 74 websites, breached statutory rules requiring UK video on demand providers to keep hardcore pornography out of the reach of children.
The two online video on demand services, “Extreme Movie Pass” and “UK Sirens”, were held to be in breach of the statutory rule requiring that material that might seriously impair under 18’s can only be made available if access is blocked to children. The Extreme Movie Pass service operated across 73 linked websites.
The services offered any user access to explicit hardcore pornographic videos that could be viewed on-demand. The content of the videos was equivalent to, or stronger than, that which could be sold only to adults in licensed sex shops if supplied on DVD.
ATVOD found that the services each broke the statutory rules in two ways. Firstly, they allowed any visitor free, unrestricted access to hardcore pornographic video promos/trailers or still images featuring real sex in explicit detail. Secondly, access to the full videos was open to any visitor who paid a fee. As the services accepted payment methods, such as debit cards, which can be used by under 18’s, ATVOD held that each service had also failed to put in place effective access controls.
The operator of Extreme Movie Pass failed to become fully compliant in accordance with a timetable set by ATVOD. The service provider has therefore been referred to Ofcom to consider whether a fine should be imposed or the provider’s right to provide a service should be suspended. To read ATVOD’s press release in full and for links to the two Determinations, click here.
European Commission consults on cross-border mergers and divisions.
The purpose of this consultation is to collect information that would allow the Commission to assess if the existing rules for cross-border operations of companies need to be changed. The questions focus in particular on the improvement of the existing EU legal framework for cross-border mergers under the Cross-Borders Mergers Directive (2005/56/EC) and on possible new EU rules for cross-border divisions of companies. The consultation follows the Commission’s 2012 Action Plan on European company law and corporate governance, which included consultations and research in these areas.
The consultation will run until 1 December 2014. Contributions are particularly sought from parties who have experience with national and cross-border mergers and divisions. For further information, click here.
Gambling Commission reminds offshore operators of imminent deadline to apply for licences to provide services to UK consumers once Gambling (Licensing and Advertising) Act comes into force.
The Gambling (Licensing and Advertising) Act 2014 comes into force on 1 October. The Act requires any operator wishing to transact with or advertise to British consumers to obtain an operating licence from the Gambling Commission. It ensures that all remote gambling operators offering services to British consumers will be subject to consistent regulation.
The Commission is reminding offshore operators that they have until midnight on Tuesday 16 September 2014 to apply for licences allowing them to continue to provide gambling services to consumers.
Licence applications must be made through the Commission’s website. If an application made by an operator currently legally transacting with consumers in Britain has not been determined by 1 October, the applicant will be issued with a continuation licence to enable them to continue to trade until completion of the application process. To read the Commission’s press release in full, click here.
UK Interactive Entertainment Association outlines policy manifesto to take UK games sector to the next level.
The UK games trade body has called for more government support to build on the introduction of Games Tax Relief and the “Next Gen Skills” report recommendations.
At Ukie’s recent Westminster Political Reception, the trade body announced a range of policy recommendations to celebrate the cultural and economic importance of the UK games sector. In particular, the event saw the launch of the new Ukie Policy Manifesto for the next Parliament that outlines initial plans for how to grow the UK games sector following the introduction of tax breaks earlier this year.
Created with input from Ukie’s members, the Policy Manifesto calls for action on three headline areas of policy support:
- support to help UK games companies grow across the UK, including regulatory stability, better infrastructure and a long term roadmap where games businesses can access public funding and support proportionate to the other screen industries;
- promotion of the UK games industry abroad, demonstrating that the UK is one of the leading videogame industries in the world, including a focus on funding, fully supporting and working with industry on trade and investment activities such as trade missions and helping UK businesses to reach overseas marketplace; and
- building a strong and diverse talent pipeline, including supporting the new “Computing Curriculum”, investing in careers guidance and extending and making permanent the Skills Investment Fund.
To read Ukie’s press release in full, click here.
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