UK insurance regulation: looking ahead to 2024

Our latest annual assessment of the UK insurance regulatory landscape reflects the huge amount of regulatory change that has occurred over the last 12 months and that is set to continue in 2024.

Milestones reached in 2023 included the first deadline for implementing the FCA’s new Consumer Duty and the passing of the Financial Services and Markets Act 2023, laying the foundations for the introduction of a new UK Solvency II regime.

We also see major developments on the horizon within the ESG and tech spaces, including an increasing focus on operational resilience and the use of critical third parties, the use of AI technology by insurers and intermediaries, and the introduction of new anti-greenwashing rules.

We explore these changes, and many more, within the context of our five key themes for 2024:

  • Post-Brexit reform of the UK regulatory framework
  • PRA focus on capital management
  • Corporate and product governance
  • Digitisation and operational resilience
  • “Green” initiatives

To access our full publication, please click here.

 

Geoffrey Maddock
Geoffrey Maddock
Partner
+44 20 7466 2067
Barnaby Hinnigan
Barnaby Hinnigan
Partner
+44 20 7466 2816
Grant Murtagh
Grant Murtagh
Partner
+44 20 7466 2158
Alison Matthews
Alison Matthews
Consultant
+44 20 7466 2765
James Bourne
James Bourne
Senior Associate
+44 20 7466 3652
Julia Danskin
Julia Danskin
Senior Associate
+44 20 7466 2160
Tim Coorey
Tim Coorey
Senior Associate (Australia)
+44 20 7466 2001

PRA consults on matching adjustment reforms: new-found freedoms or simply different chains?

The PRA’s latest consultation on reforming the UK’s insurance regulatory regime proposes a number of changes to the matching adjustment rules. This is the second PRA consultation to follow the UK Government’s Solvency II review, which confirmed that the post-Brexit Solvency II framework should be better aligned to the structural features of the UK insurance sector. The changes should also support the Government’s aim of encouraging insurers to provide more long term capital to the UK economy.

CP19/23 outlines how the PRA proposes to pull off a magic trick of sorts: allowing insurers freedom to invest in riskier assets without increasing the risk that those same insurers will run into financial difficulties.  A lot is riding on this. The Government is hoping that the Solvency II reforms, of which this consultation is a significant part, will free up billions of pounds of capital for investment. It is hoped that those investments will spur growth in the UK’s economy, and so be good for everybody in the UK.

As is generally the case with regulatory reform of this importance, the changes that insurers, and others, will welcome come with significant strings attached. There is a lot to work through in the consultation, and insurers will need to establish whether the increased costs are proportionate to the additional returns (and risks) that might accrue.

We look forward to working with insurers and our clients more generally to help them consider the proposals. The potential prize on offer is significant, and the deadline for feedback on the proposals is 5 January 2024. Now is the time to consider whether the proposals need to be changed, such that the aim of unlocking large amounts of capital to help grow the wider economy can be realised.

In our publication here, we discuss the proposed regulatory changes in further detail and provide our thoughts on the impact that these changes are set to have on insurers, as well as potential recipients of insurer finance.

 

Geoffrey Maddock
Geoffrey Maddock
Partner
+44 20 7466 2067
Barnaby Hinnigan
Barnaby Hinnigan
Partner
+44 20 7466 2816
Grant Murtagh
Grant Murtagh
Partner
+44 20 7466 2158
Alison Matthews
Alison Matthews
Consultant
+44 20 7466 2765

UK insurance regulation: looking ahead to 2023

2022 proved to be as busy for insurance firms and regulators as we predicted last January. Yet more change can be expected in 2023.

In Brexit-related news, the Treasury is taking forward plans to change the UK’s Solvency II regime. Its announcement coincided with the Autumn statement, signifying the importance attributed to Solvency II reforms within the Government’s wider post-Brexit plans for the economy.

Solvency II reforms are just one of a series of regulatory changes proposed by the Government in its flagship Financial Services and Markets Bill (FSM Bill). In tandem with the FSM Bill, the Treasury has announced a series of reforms, known as the Edinburgh Reforms, which are similarly aimed at driving growth and competitiveness in the financial services sector post-Brexit. (See our recent blog post and webcast series for more details.)

Meanwhile, the FCA has published final rules and guidance on the new Consumer Duty in what it describes as a “paradigm shift” in its expectations of firms. The challenge for firms to meet implementation deadlines of 31 July 2023 for new and existing products and 31 July 2024 for closed products and services remains considerable.

Unsurprisingly, ESG continues to be another key focus, with ESG-related transparency set to be the theme for the next 12 months. In early January, the PRA’s statement of supervisory priorities for 2023 confirmed its continued focus on the financial risks that climate change presents for the sector.

Other priorities for the PRA include consulting on the introduction of a resolution framework for insurers and on a new regulatory framework for diversity, equality and inclusion (DEI).

We consider these, and other, issues more fully here.

Geoffrey Maddock
Geoffrey Maddock
Partner
+44 20 7466 2067
Barnaby Hinnigan
Barnaby Hinnigan
Partner
+44 20 7466 2816
Alison Matthews
Alison Matthews
Consultant
+44 20 7466 2765
Grant Murtagh
Grant Murtagh
Of Counsel
+44 20 7466 2158

HM Treasury announces final reform package following review of Solvency II

A version of this article was first published on Thomson Reuters Regulatory Intelligence.

The Treasury’s plans to reform Solvency II have entered their next phase after it published the results of its April 2022 consultation. This coincided with its Autumn statement, signifying the importance attributed to Solvency II reforms within the Government’s wider plans to create a vibrant post-Brexit economy.

A reassessment and loosening of certain aspects of the current regulatory framework are expected to release significant amounts of capital, enabling insurers to invest in illiquid assets in the real economy. Aviva estimates it could make at least £25 billion worth of capital investment over the next 10 years across the UK if the reforms go ahead. The ABI view is that the changes would allow industry to invest over £100 billion over the same period in productive finance, including UK social infrastructure and green energy supply.

The Treasury argues that post-Brexit freedoms to change laws inherited from the EU mean that it can create a Solvency II regime that is better tailored to the UK insurance market.  Risk margin reforms undoubtedly reflect widespread agreement that the current rules are deficient.

Changes proposed by the PRA to fundamental spread (FS) methodology have not, however, made it into the final package.  PRA concerns that Solvency II reforms must maintain the overall integrity of the regime have clearly been overruled by the Government on this occasion.  It will be interesting to see how the PRA reacts over the coming months and years, including in its interactions with future governments.

While the Treasury’s proposals indicate a clear direction for reform, it could be some time until the detail is known. Some reports suggest it could be the end of 2024, or possibly 2025, before the changes come into force.

Background

There has been long-standing debate on the suitability of certain aspects of the current Solvency II regime for the UK insurance market. For example, the current methodology for calculating the risk margin is widely criticised for its unnecessarily burdensome effect on life insurers.

However, whilst there is general agreement that reforms to Solvency II could help establish a more appropriate regime for UK insurers, there has been less agreement on how exactly it needs to change. The PRA, in particular, has argued for caution in making changes to the Solvency II regime that release capital for investment but do not meet with the need for prudence, consistent with its safety and soundness and policyholder protection objectives. In a speech given in July 2022, Sam Woods of the PRA stated as follows:

“Brexit gives us an opportunity to rewrite the insurance regulations we inherited from the EU – and in doing so help drive further investment in the economy. But we need to be clear that this is not a free lunch. If changes simply loosen regulations which were over-cooked by the EU, without tackling other areas where regulations are too weak, then we are putting policyholders at risk.”

In an effort to build consensus, the Treasury released a consultation paper on 28 April 2022 calling for feedback on four key areas for reform:

  • a substantial reduction in the risk margin;
  • reforming the FS of the matching adjustment;
  • increasing investment flexibility for matching adjustment portfolios; and
  • reducing unnecessary reporting and administrative burdens.

Simultaneously, the PRA issued a discussion paper (DP2/22) setting out its views on the Treasury’s proposed reforms to the risk margin and matching adjustment. In a feedback statement (FS1/22), also issued on the same day as the government’s Autumn Statement, the PRA notes its support for the objectives of the Solvency II review but stops short of saying it supports the outcome.

HMT package of reform

The Treasury’s reform package carries over most of the proposals put forward in its consultation paper, with some notable differences.

Risk margin

Unsurprisingly, changes to the risk margin are going ahead, including a 65% reduction for long-term life insurers under recent economic conditions. The Government anticipates that this change will, amongst other things, free up significant amounts of capital, removing a barrier to lower product prices and higher annuity yields and reduce the volatility of life insurers’ balance sheets.

For general insurance business, the reduction will be around 30%.

Fundamental spread

The “most challenging element of the debate” was on the construct of the FS. The PRA wants to change the current methodology to reflect various concerns, including that the FS does not, in its view, allow fully for uncertainty around credit risk. The Treasury has rejected the PRA’s proposals on the basis that it has been impossible to reach a consensus, deciding to leave the design and calibration of the FS as it stands. It will, however, allow the

PRA to use three new measures aimed at safeguarding policyholders:

  • the introduction of new stress test requirements;
  • requiring nominated senior managers with formal regulatory responsibilities under the SMCR to sign an attestation that the firm’s determination of the FS, as recognised in its accounting records, properly reflects all retained risks; and
  • allowing insurers to apply a higher FS on a voluntary basis (which would presumably be done in response to a senior manager having concerns about signing the attestation).

The sting in the tail for firms of preserving the current FS methodology may be the introduction of a new formal attestation requirement. There is no confirmation yet of how often this attestation will be needed and of what it will need to cover. However, the personal liability that attaches to the senior manager who is responsible for giving the attestation means that processes will need to be established to safeguard their position and that of the firm. Careful consideration will need to be given, for example, to how the attestation is drafted and appropriate diligence should be conducted to obtain the requisite level of comfort in the statements that are being made.

It is also possible that the current reforms are introducing political risk into the system. Specifically, if a new government were formed, can anyone say with certainty that the PRA would not convince them that the current reforms have unduly weakened the regulatory regime overall? Given its clear stance on this issue, it is not difficult to imagine the PRA at least raising the issue.

Increasing investment flexibility

The Government is taking forward proposals to lift some of the current restrictions on assets that can be brought into firms’ matching adjustment portfolios. In particular, requirements that cash flows from matching adjustment portfolios must be fixed will be replaced by a requirement that cash flows are “highly predictable”. Additional flexibility to include assets with prepayment risk or construction phases will also broaden matching adjustment eligibility.

These changes, together with the changes to the risk margin, are expected to free up capital that could be used to increase insurer investment in long-term productive assets, most notably in infrastructure. Indeed, some major UK life insurers have already publicly said that this is what they intend to do. It is also hoped that there will be less need for asset restructuring to meet matching adjustment criteria.

Reducing reporting and administrative burdens

As part of its efforts to “slash red tape lingering from the EU”, the Government is introducing certain changes aimed at reducing the administrative burden on firms and creating a more favourable environment for smaller insurance firms.

These include removing requirements for UK branches of overseas insurers to calculate branch capital requirements and to hold assets locally to meet those requirements. This is an issue that came to the fore as a consequence of groups restructuring to mitigate the impact of Brexit. The argument in support of this change is that a branch capital requirement is not needed if the “parent” firm is properly capitalised under its home state’s regulatory regime. More generally, the PRA has also indicated, following its consultation earlier this year, that it expects to be able to reduce the reporting burden for insurers significantly as part of the reforms.

The Treasury also intends to increase the thresholds for the size and complexity of insurers before they become subject to the UK’s on-shored version of Solvency II.

Further observations

Additional points raised by the Treasury’s package of reforms include the following:

  • Despite suggestions in April’s consultation paper that the Government might look to restrict the use of some assets that are released from the matching adjustment under these reforms (eg, to require their investment in infrastructure), nothing in its response suggests this will happen.
  • Until the drafted rules and regulations have been released, we do not have a detailed picture of what the final reforms will look like. As always, the devil may be in the detail (for example, is some elaboration of what “highly predictable” means to be offered?) although it seems unlikely that significant inroads will be made into the commitments made by the Treasury.
  • What does seem clear is that the Government is not content to let the PRA make all the rules needed to implement these reforms, and therefore it intends to legislate on certain aspects of the proposed reforms that it feels strongly about, such as the risk margin.
  • It will nonetheless be interesting to see how the PRA responds to the Treasury’s package of reforms given its clear reservations over some of the changes.

 

Geoffrey Maddock
Geoffrey Maddock
Partner
+44 20 7466 2067
Grant Murtagh
Grant Murtagh
Of Counsel
+44 20 7466 2158
Alison Matthews
Alison Matthews
Consultant
+44 20 7466 2765

 

UK insurance regulation – looking forward to 2022

After a year of upheaval for the UK insurance sector in 2021, there seems little prospect of 2022 being any quieter.

From a regulatory perspective, 2021 began with the end of the Brexit transition period.  And while firms operating in UK insurance markets have been insulated from the full impact of Brexit during 2021, this is set to change in 2022.  Solvency II reforms can now also be introduced in the UK without regard to the constraints of EU membership.

Meanwhile, the FCA has embarked on an ambitious transformation programme, putting consumer protection at the heart of its focus on becoming a “more assertive, innovative, and adaptable” regulator.  The introduction of a new Consumer Duty is expected to bring about a step change in how financial sector firms behave.  Other recent developments carrying over into 2022 include proposals to improve regulated firms’ oversight of Appointed Representatives.

ESG remains, of course, high on the agenda of firms and regulators worldwide, with increasing engagement at Board and senior executive level on a range of issues.  Notably, COP26 brought climate change into sharp focus.  The PRA and the FCA are also looking to “accelerate the pace of meaningful change” in diversity and inclusion in the financial services sector.  Further activity can be expected in relation to each of “E”, “S” and “G” during 2022.

Other current areas of focus are the government’s post-Brexit review of the regulatory framework for financial services and the operational resilience of firms, including the challenges brought by Covid-19.

Our briefing, which can be found here, looks at some of the key regulatory developments that have taken place in 2021 and considers the outlook for 2022.

Geoffrey Maddock
Geoffrey Maddock
Partner, London
+44 20 7466 2067
Alison Matthews
Alison Matthews
Consultant, London
+44 20 7466 2765
Grant Murtagh
Grant Murtagh
Of Counsel, London
+44 20 7466 2158
Barnaby Hinnigan
Barnaby Hinnigan
Partner, London
+44 20 7466 2816
Hywel Jenkins
Hywel Jenkins
Partner, London
+44 20 7466 2510
Benedicte Perowne
Benedicte Perowne
Senior Associate, London
+44 20 7466 2026

Court of Appeal Clarifies Approach to Interpretation of EU Retained Law

A recent decision of the Court of Appeal has clarified the approach that English courts should take to retained EU law following the UK’s withdrawal from the EU.  The case concerned the interpretation of an EU regulation which until 31 December 2020 (“IP completion day“) had direct effect in the UK but which now applies in the UK by virtue of the European Union (Withdrawal) Act 2018 (“EUWA“).

Continue reading

New Brexit Legal Guide section available: Insurance

The updated Insurance section of our Brexit Legal Guide is now available.

This provides a useful overview, amongst other things, of whether the end of the transition period:

  • requires incoming EEA (re)insurers and (re)insurance intermediaries to apply for, and obtain, full authorisation for their UK operations;
  • will impact UK firms wishing to conduct activities in other jurisdictions without the benefit of passporting rights; and
  • will result in the UK’s regulation of (re)insurers following Solvency II closely or departing from its standards.

If you would like to discuss specific arrangements for support on any of the issues covered by the guide, please do ask your regular Herbert Smith Freehills relationship contacts, or otherwise any of our experts listed here.

Geoffrey Maddock
Geoffrey Maddock
Partner, London
+44 20 7466 2607
Barnaby Hinnigan
Barnaby Hinnigan
Partner, London
+44 20 7466 2816
Alison Matthews
Alison Matthews
Consultant, London
+44 20 7466 2765
Grant Murtagh
Grant Murtagh
Of Counsel, London
+44 20 7466 2158

France sets out approach to post-Brexit servicing of policies held by UK expats

In February 2019, EIOPA published a series of recommendations (the “Recommendations“) for the insurance sector relating to the UK’s withdrawal from the EU (see our earlier blog post here).

The French regulator, the Autorité de contrôle prudentiel et de resolution (“ACPR“), has indicated that it does not intend to comply with Recommendation 6, relating to insurance policies sold in the UK by UK insurers to policyholders who have since relocated to an EEA state (“UK expats“).

UK insurers needing to service policies held by UK expats living in France post-Brexit should consider the ACPR announcement carefully. Some may need to secure passporting rights into France before the UK leaves the EU.

Background – Solvency II and third country firms

As widely discussed over the past few years, a risk associated with the UK’s withdrawal from the EU is that UK insurers with policyholders in EEA states will not be able to service those policies post-Brexit unless they have established an authorised branch in each country (or unless the policies have been transferred by the time of Brexit to an EEA carrier). This is because, whilst Article 162 of the Solvency II Directive provides for the authorisation of EEA branches of third country insurers, it is silent on how cross-border services business (often referred to as “non-admitted” insurance) from a third country (including the UK post-Brexit) should be treated and there is no consistent approach.

As the possibility of a country leaving the EU has not previously been seen as something for which extensive provision needs to be made in European legislation, little attention has been given to such differences. However, the risk to EEA policyholders of being unable to claim, post-Brexit, under policies held with UK insurers highlights the importance of understanding limits on individual state discretion in this area.

What has EIOPA said?

Under the Solvency II regime, cross-border insurance services are provided where an insurer established in one EEA state covers risks or commitments located in another EEA state.

Recommendation 6 (Change in the habitual residence or establishment of the policyholder) reads as follows:

23. Where a policyholder with habitual residence or, in the case of a legal person, place of establishment in the UK concluded a life insurance contract with a UK insurance undertaking and afterwards the policyholder changed its habitual residence or place of establishment to a EU27 Member State, competent authorities should take into account in the supervisory review that the insurance contract was concluded in the UK and the UK insurance undertaking did not provide cross-border services for the EU27 for this contract.

24. Competent authorities should apply the same approach to non-life insurance contracts that do not relate to buildings or to buildings and their contents or to vehicles.

In summary, EIOPA takes the view that the state of the risk/commitment under an insurance contract is fixed from the date a policy incepts. It does not change, therefore, if a policyholder moves his habitual residence (or establishment) from the UK to France (or any other EEA state) after the policy has been taken out.

Applying this approach, a UK insurer that continues to pay claims today after a UK policyholder has relocated to another EEA state will not be carrying on cross-border business and does not rely on passporting rights to make those payments. Post-Brexit, that insurer should also be able to continue to pay claims into France, say, without needing to obtain a local authorisation to replace lost passporting rights.

In our experience, most, if not all, UK insurers take the same view on this as EIOPA. They have not, as a consequence, included policies held by UK expats in any Brexit-related Part VII schemes transferring policies to an EEA carrier.

What has the ACPR said?

In a statement published on its website on 8 November 2019, the ACPR stated that French law requires it to conclude that the state of the risk/commitment would move with a UK policyholder to France on a change of habitual residence or establishment (as the case may be). For a UK insurer to service that policy it would, therefore, need to have regulatory permission to conduct insurance business in France. Pre-Brexit, passporting rights held by the UK insurer would be sufficient. Post-Brexit, regulatory permission to conduct business in France would be needed.

If the ACPR’s announcement had stopped here, UK insurers needing to service policies held by UK expats post-Brexit would have been placed in an extremely difficult position. Helpfully, however, transitional rules aimed at ensuring that Brexit does not interrupt the payment of claims by UK insurers to policyholders in France appear to provide a solution.

In brief, French legislation (known as the Brexit Ordinance) allows UK insurers to perform their obligations under contracts written before Brexit, including under contracts written with UK expats, provided that, on the date the UK leaves the EU, the insurer holds passporting rights to operate in France.

ACPR has also confirmed that the Brexit Ordinance will not apply to renewals or to contracts providing for the payment of new premiums. This does not, however, prohibit the payment of “mandatory premiums” payable by the policyholder under the contract.

What has the PRA said?

On 12 November 2019, the PRA published a statement highlighting the ACPR’s comments. It encouraged firms to seek legal advice and consider any risk arising from the ACPR approach to affected policyholders as soon as possible. Specifically, firms should consider the need to secure passporting rights before exit day to ensure that they could can meet their obligations to UK expats post-Brexit by relying on the Brexit Ordinance.

Our view

The extension of run-off rights under the Brexit Ordinance to contracts held by UK expats with UK insurers is welcome. Without this concession, many UK insurers without a French branch would be concerned that they could not pay claims to UK expats, including those moving to France after Brexit, without breaking French law.

The impact of the ACPR’s comments on renewals and the payment of additional premium is likely to vary by type of policy. In the case of general insurance, UK firms should be able to take advantage of the Brexit Ordinance, at least until they renew (usually annually). In the case of long term business, annuity policies in payment at the time of Brexit and that have been secured by the payment of a single premium, should fall within France’s run-off regime. Drawdown and protection policies should also be able to benefit.

More difficult, perhaps, are long term savings contracts, such as pensions. Whilst, in a sense, no premium is ever mandatory as a policyholder can always lapse the policy, and firms should take advice, we expect that in context this must mean a payment of premium which is mandatory if the cover is to be maintained.

The ACPR comments that its approach to this issue is mandated by French case law and regulation. We would question whether the domestic law of any EEA state, rather than EU law, should determine the state of the risk or commitment under an insurance policy for the purposes of Solvency II rules on passporting.

Firms that need to rely on the Brexit Ordinance to meet their obligations to UK expats in France will need to ensure that they hold passporting rights into France at the date of the UK’s withdrawal from the EU (currently due to be 31 January 2020). Some insurers will already hold those passporting rights and need take no further action. Others, who have probably never sought to make sales into France, may need to secure their passporting rights before the UK leaves the EU. It is important that they do so. There is no de minimis threshold for the application of the French regime which means that the relocation of a UK policyholder to France (before or after Brexit) could put a UK insurer in breach of French law if it has not taken steps to obtain passporting rights before Brexit.

 

Geoffrey Maddock
Geoffrey Maddock
Partner, London
+44 20 7466 2067
Barnaby Hinnigan
Barnaby Hinnigan
Partner, London
+44 20 7466 2816
Alison Matthews
Alison Matthews
Consultant, London
+44 20 7466 2765
Grant Murtagh
Grant Murtagh
Senior Associate, London
+44 20 7466 2158

Updated Brexit Legal Guide launched

We released the latest version of our Brexit Legal Guide yesterday. Below is a message from our Chair and Senior Partner, James Palmer, which accompanied the updated guide.

Dear clients and professional colleagues,

The outcome of the June 2016 UK referendum on EU membership ushered in a period of increasing political turmoil in the UK. When I wrote an introduction to the first edition of this legal guide my colleagues and I had a clear view that leaving the EU would take far longer and be far more complex than most other commentators were saying, but I did not anticipate then that over three years later we would have so little clarity on the UK and EU’s long term relationship with each other.  Nor that polarisation of views on all sides would have increased still further, leading to political deadlock. This updated Brexit Legal Guide addresses the legal position if the UK leaves the EU with or without a deal and picks out the key pieces of legislation that will soon be in force if the UK leaves the EU without a deal.  I hope you will find it useful.

Throughout the Brexit process our team at Herbert Smith Freehills have worked across our firm to help clients in all markets and parts of the world in preparing for this major change.  For those who had to make significant changes in order to continue to carry on business in the EU, particularly financial institutions, many of these changes were made in time for the original leaving date of March 29th this year.  Across a range of sectors, clients have set up new subsidiaries, acquired new regulatory approvals in the EU or the UK, prepared for changed distribution channels and sought to protect their people working across countries. For businesses that trade in goods between the UK and the EU, however, although careful plans have been laid, the time of testing will not come until the rules at the frontiers and within the EU and the UK actually change – this could be at the end of next month or potentially as late as the end of 2022.

At the time of writing, the Government in the UK has lost its parliamentary majority and Brexit is dominating the political context, driving out other factors which of course may also be relevant if, as seems likely, a general election is held within the next couple of months.  The political situation is so fluid that anything I say about the options to resolve the crisis, and how they may affect the timing and nature of Brexit,  is likely to be out of date by the time this message goes out.  We are all experiencing unusually uncertain times.

What I can say, is that we have worked in depth across our practice from offices across Europe, Asia and around the world, as well as from the UK, to help clients across sectors on a wide range of Brexit issues since before the 2016 referendum.  Our differentiating expertise has been recognised both by external commentators and by our close involvement in working with governments and regulators to develop solutions to Brexit related challenges for businesses.  Our long tradition of involvement at the interface of law and public policy development is one to which we remain committed.

If you would like to discuss specific arrangements for support through the risk of a no-deal exit or on dispute risks that may arise, or on any other questions or challenges you have, please do contact your regular Herbert Smith Freehills relationship contacts, or otherwise any of our experts listed here.

Yours faithfully,

James Palmer

James Palmer
James Palmer
Chair and Senior Partner
44 20 7466 2327