Written Ministerial Statements

Tuesday 15th May 2012 Written Statements

Tuesday 15 May 2012

Regional Growth Fund Update

Tuesday 15th May 2012 Written Statements

[The Minister of State, Department for Business, Innovation and Skills (Mr Mark Prisk)]

The regional growth fund (RGF) has allocated conditional offers to the value of £1.4 billion to projects and programmes during the first two rounds of bidding during 2010 and 2011. Below is an update on progress with these projects.

In November 2011, due to the RGF programme’s success, an additional £1 billion was allocated to the fund by the Chancellor, and round 3 opened for bidding in February 2012. The RGF objectives for round 3 remain the same, and the application process has been simplified.

The RGF secretariat has been travelling across England to encourage and support potential bidders and will continue to do so until round 3 closes at noon on 13 June.

Rounds 1 and 2—update

From the previous rounds, 176 successful bids have been conditionally allocated £1.4 billion.

This translates into 237 final offer agreements because some bids comprise of multiple counter-parties.

Of the 237 agreements:

82 have a final agreement in place, to a value of almost £610 million. These projects are able to draw down their funding. These projects leverage over £3 billion of private sector investment.

60 have agreed terms and conditions including leverage, funding and jobs—these will now proceed through due diligence and represent a further £4 billion of private sector investment.

10 have withdrawn from the RGF process (see list at Annex A), which has released up to £15 million to be recycled into the RGF, or used at Ministers’ discretion to support companies and local areas identified as experiencing economic difficulties.

85 companies have received draft offers, but are still considering terms and conditions.

The next update on RGF progress will be in July 2012.

Annex A - List of withdrawn projects

Thales Properties Ltd (Leicester)

Cumbrian Holdings (County Durham)

Zegen (Wilton) Limited (Leeds)

Ames Goldsmith UK Ltd (Liverpool)

Messier-Dowty Ltd (Gloucester)

Rapiscan Systems (Redhill)

T&N Plastics Limited (Grimsby)

Conitech (Northumberland)

Irwin and sons (Dungannon)

Diodes Zetex (Oldham)

Special Educational Needs and Disability (Green Paper)

Tuesday 15th May 2012 Written Statements

[The Minister of State, Department for Education (Sarah Teather)]

I am pleased to announce the publication today of “Support and aspiration: A new approach to special educational needs and disability—progress and next steps”, the Government’s response to the consultation on the special educational needs and disability Green Paper. Copies will be placed in the Libraries of both Houses.

As well as setting out the Government’s response to the consultation it sets out the progress made and the next steps in taking forward the proposals in the Green Paper. A separate summary report of the consultation responses is being published on the Department for Education’s website at the same time.

The Government set out in the Green Paper their vision for improving the education and life outcomes of children and young people who are disabled or have special educational needs and our proposals for improving the support that they and their families receive. There has been keen interest in the Green Paper and strong support for our proposed reforms. Almost 2,400 responses were received to the consultation from a wide range of individuals and organisations. I am grateful to everyone who took the time to reply for their thoughtful and informed responses.

The Government are committed to achieving the ambitious programme in the Green Paper. Progress has been made in taking forward the commitments made. But there is more to do. We owe it to the children, young people and families who get a poor deal from the current system, and to those who work with and support them, to make sure we get those changes right. That is why we have established 20 local pathfinders involving local authorities and their local health partners who are testing out the reforms and building the knowledge and skills that will be needed for their successful implementation.

The practice developed by the pathfinders will be shared widely with other local areas. An interim evaluation of the pathfinders will be published by October 2012, with a final evaluation report following in 2013.

The Queen’s Speech announced the Government’s intention to bring forward legislation in the current session of Parliament to take forward the Green Paper reforms. These changes are vital for children, young people and families and we need to begin the legislative process in the current session in order to meet the commitments given in the Green Paper.

Our aim is to publish a draft Bill in the summer which would be informed by early lessons learned from the pathfinders. There would then be further opportunities for lessons learned from the pathfinders to inform the pre-legislative scrutiny stage and the Bill itself. Our intention remains, subject to Parliament’s approval, to implement the

reforms from 2014. Lessons learned from the pathfinders and evaluation of their activity will inform how the reforms are implemented.

The Bill would include provision for:

Every local authority to develop and publish a local offer of support for children, young people and families—including from early years settings, schools and colleges and the voluntary sector and from health and social care services;

A new, single assessment process and education, health and care plan from birth to 25 with arrangements comparable to statements for young people over 16—whether they are in school or at college—this is a significant change and will help us to get better transitions to adult life, independence and the world of work;

All families with an education, health and care plan to be offered a personal budget for their support;

Ensuring that services for disabled children and young people and those with special educational needs are planned and commissioned jointly by local authorities and clinical commissioning groups and that there are clear duties on all of the agencies involved, building on the reforms to the health services introduced by the Health and Social Care Act 2012 and drawing on the recommendations of the Children and Young People’s Health Outcomes Forum;

Parents to have the right to express a preference for any state funded school, including academies and free schools, and have their preference considered under the same criteria as for maintained schools;

Families to try mediation before they appeal to the tribunal;

And it will seek a power to trial giving children the right to appeal to the tribunal.

We are working across Government and with our local and national partners to put the reforms in place, drawing on the findings from the pathfinder programme.

Fuel Poverty Advisory Group

Tuesday 15th May 2012 Written Statements

[The Minister of State, Department of Energy and Climate Change (Gregory Barker)]

The coalition Government, as part of their reform of the public bodies sector, have committed to undertake triennial reviews of all Executive and advisory non-departmental public bodies.

As part of this process I am announcing today the triennial review of the Fuel Poverty Advisory Group (FPAG).

FPAG is a non-departmental advisory body of the Department of Energy and Climate Change, which consists of a chairman and senior representatives from the energy industry, charities and consumer bodies. The role of the group is to:

Consider and report on the effectiveness of current policies aiming to reduce fuel poverty;

Consider and report on the case for greater co-ordination;

Identify barriers to reducing fuel poverty and to developing effective partnerships and to propose solutions;

Consider and report on any additional policies needed to achieve the Government’s targets;

Encourage key organisations to tackle fuel poverty, and to consider and report on the results of work to monitor fuel poverty.

The aims of the review are:

to provide a robust challenge of the continuing need for an NDPB to carry out these roles—both their functions and their form; and

if it is agreed it should remain as an advisory NDPB, to review the control and governance arrangements in place to ensure that the public body is complying with recognised principles of good corporate governance.

There will be a short consultation process and we welcome views from interested stakeholders regarding the role of FPAG. We will publish the findings of the review on the DECC website in the summer.

Agricultural and Fisheries Council

Tuesday 15th May 2012 Written Statements

[The Secretary of State for Environment, Food and Rural Affairs (Mrs Caroline Spelman)]

The Minister of State, Department for Environment, Food and Rural Affairs, my right hon. Friend the Member for South East Cambridgeshire (Mr Paice), represented the UK on 26 April covering the agriculture items. The Under-Secretary of State for Environment, Food and Rural Affairs, my hon. Friend the Member for Newbury (Richard Benyon), represented the UK on 27 April covering fisheries business. Richard Lochhead MSP and Alun Davies AM also attended.

The main focus of Agriculture Council was two table rounds on CAP reform, covering several elements of the proposed direct payment scheme.

On young and small farmers, member states repeated their broad support for the measures but the majority view was that they should be voluntary at national level. The UK argued the scheme should be for genuine new entrants and not hereditary. The main disagreement on small farmers was their exemption from cross-compliance and greening. The UK and others opposed a total exemption. The Commission insisted the proposal would deliver benefits to farmers and administrations.

Member states were split over proposals to allow subsidy to be coupled to production. The UK and others warned against any expansion of coupled support. Others wanted to broaden the scope of the proposals and take in new sectors, including pigmeat and tobacco. The presidency and Commission suggested that the balance of the proposals was about right.

Most member states were comfortable with the Commission’s proposed pillar 1 scheme for areas of natural constraint, on the basis that it would be voluntary.

The Commission expressed openness to an alternative approach on the definition of an active farmer. This was broadly welcomed, as was the presidency’s recent text removing the income test element.

The UK and other member states underlined their strong opposition to the principle of capping of direct payments at farm level. Others were in principle in favour of the proposal, but would prefer a simpler system.

On convergence of payment rates within member states and regions, many, including the UK, reiterated the need for national flexibility on the speed of the transition.

There were six items under any other business.

(i) A Commission presentation of its communication on the promotion of EU agricultural products which would lead to a legislative proposal by the end of 2012.

(ii) Hungary supported by seven new member states raised the recent decision to limit the funding available to producer groups in the fruit and vegetables sector, urging reconsideration. The Commission responded that the budget ceiling was necessary.

(iii) Poland with some support from other member states urged the Commission to reintroduce milk export refunds and to raise intervention prices for butter and skimmed milk powder in the medium-term. The Commissioner replied that prices had risen throughout 2011 and recent price falls were in line with seasonal norms: there was no justification for market intervention.

(iv) The Commission updated member states on the implementation of the sow stall ban. Member states must be fully compliant on 1 January 2013 and there would be no extension. Current data suggested that only 16 would be. The UK gave the Commission full support adding that there were significant welfare benefits and experience suggested that those in compliance would see prices rise.

(v) The Czech Republic explained that recent incidences of industrial salt and adulterated egg powder in food, in Poland, demonstrated the requirement for full transparency between member states. Poland responded by saying their food was safe, that the Polish inspection services had launched inquiries into both incidents, and a risk assessment had concluded that the industrial salt incident had posed no risk to human health.

(vi) France drew attention to a recent scientific study which drew a link between bee health and the use of the pesticide thiamethoxame. The European Food Safety Agency was verifying the study and the Commission confirmed they would take any necessary action once the EFSA evaluations had been completed. The UK and the Netherlands both welcomed urgent EFSA consideration of the study.

On Friday 27 the Council debated two aspects of common fisheries policy (CFP) reform: regionalisation and transferable fishing concessions (TFCs).

Under regionalisation the Commission highlighted two key aspects as desirable: increased involvement of the industry and stakeholders, and a simplified decision making procedure. The Commission stressed that regionalisation would only ever be an option for member states and would never be imposed.

The UK, along with other member states supported significant regionalisation allowing member states in any given area to agree the detailed technical measures needed in their shared fisheries, in consultation with the advisory councils. Also where agreements were reached these should be put into effect through EU implementing measures, and the absence of an agreement should not give the Commission a reason to impose measures, but proceed through co-decision. The majority of member states supported this approach. The Commission responded that there was a need to balance the ambition of member states to develop decentralised models and the efficiency of the CFP.

On the proposed TFCs the Commission stressed the need to reduce capacity and the TFC was the best method to so, and were prepared to be flexible on the detail. They were prepared to build in flexibility and safeguards, for example to avoid over-concentration in too few hands, and stressed that member states were obliged to certify by 1 January 2013 that they were compliant with existing capacity ceilings.

Although member state views on the detail differed to a degree, most spoke against the imposition of TFCs, with a few supporting the principle of TFC’s only on a voluntary basis.

The UK stressed that detailed decisions on allocations should be left to the member state. Only a few supported mandatory TFCs for larger vessels and long distance vessels. The majority of member states agreed that any trading should be between existing fishing operators. Some asked for funding from the EMFF for vessel scrapping aid to allow capacity reduction. The Commission undertook to consider member states’ comments.

Over lunch fishery ministers discussed the socio economic aspect of CFP reform, some underlining the importance of supporting fisheries communities, others looking for special funding to support hard pressed communities.

Winterbourne View (Hospital)

Tuesday 15th May 2012 Written Statements

[The Minister of State, Department of Health (Paul Burstow)]

I promised to update the House about ongoing activity in relation to Winterbourne View private hospital and other services for people with learning disabilities.

The House will wish to note that nine people employed at Winterbourne View hospital have pleaded guilty and have been referred for sentencing reports. A further two people have pleaded not guilty and are due back in Bristol Crown court on 6 August. Once the criminal proceedings are completed, we expect the serious case review, chaired by Dr Margaret Flynn, to be published.

The Care Quality Commission (CQC) has now completed its programme of focused inspections of 150 hospitals and care homes for people with learning disabilities. The reports from these inspections are being published in batches, and the final 10 reports were published on 9 May 2012. They can be found at: www. cqc.org.uk/LDReports?1atest. These reports have found poor practice in some of the units, and common areas of concern include limited person-centred care, limited appropriate activities and a lack of monitoring and learning from incidents of restraint. CQC will publish a summary national report of these inspections in the summer.

The final departmental review of Winterbourne View will draw its conclusions on the basis of the findings from the serious case review and evidence from the other investigations and reports that have been undertaken, and so will be published soon after the serious case review.

In recognition of the seriousness of this issue, the Department intends to publish an interim report before summer recess, based on the findings of the CQC summary report and other evidence from the engagement with key partners, which will set out proposed actions and solutions.

I will continue to update the House.

Equalities/Equality and Human Rights Commission

Tuesday 15th May 2012 Written Statements

[The Secretary of State for the Home Department (Mrs Theresa May)]

I am today announcing the outcome of the red tape challenge spotlight on equalities, alongside the Government response to the consultation on the reform of the Equality and Human Rights Commission.

The equalities red tape challenge package balances the need to provide important legal protection from discrimination with identifying which measures in the Equality Act 2010 are placing unnecessary or disproportionate burdens on business.

The package aims to reduce these burdens through delaying or repealing the law. We have today published consultation documents on the removal of provisions relating

to:

employer liability for the harassment of an employee by a third party e.g. a customer;

the power of tribunals to make wider recommendations in a successful discrimination case; and the statutory mechanism by which individuals can obtain information where they think an employer, or service provider, has acted unlawfully towards them.

We will:

proceed with the repeal of the socio-economic duty;

delay commencement of the dual discrimination provisions in the Equality Act 2010;

delay commencement of reasonable adjustments to common parts provisions.

We have also looked again at the public sector equality duty (PSED). This Government have a strong commitment to equality of opportunity. But we also have a strong desire to reduce unnecessary bureaucracy where it exists and consider alternatives to legislation. We committed last year to assess the effectiveness of the PSED specific duties. We have decided to bring forward that review and extend it to include both the general and specific duties to establish whether the duty is operating as intended.

A proportionate approach to legislation goes hand in hand with our plans for the EHRC. We want the EHRC to become a valued and respected national institution. To do so, we believe it must focus on the areas where it can add value—as an independent equality body and ‘A-rated’ national human rights institution. And, it must be able to show that it is using taxpayers’ money wisely.

Taking account of the views expressed in our consultation: “Building a fairer Britain: Reform of the Equality and Human Rights Commission”, we have decided to scrap vague, unnecessary and obsolete provisions from the Equality Act 2006 to focus the EHRC on its core functions.

In parallel, we are implementing a strong package of non-legislative measures, including:

recruiting a new chairman, to succeed Trevor Phillips who is retiring, and a new smaller board;

conducting a comprehensive review of the EHRC’s budget;

implementing tighter performance and financial controls set out in a new framework document.

We consider that this package has the potential to deliver the change in the EHRC’s performance that we all want to see, but we will review the EHRC’s progress at its next triennial review in autumn 2013.

Copies of the consultation documents on removal of specific provisions in the Equality Act 2010, and the Government response to the EHRC consultation will be placed in the House Library and can also be found on the Home Office website at the following link: http://www.homeoffice.gov.uk/equalities

Olympics (Airspace Restrictions)

Tuesday 15th May 2012 Written Statements

[The Secretary of State for Transport (Justine Greening)]

On 7 March 2011 the Government announced our initial plans to introduce temporary airspace restrictions during the London Olympic and Paralympic games to help protect key games locations from potential airborne risks. We also committed to undertake further work to evaluate the potential impact of these measures before final decisions were made. This work, undertaken in conjunction with the aviation sector and the Government’s security experts, led to a revised set of planned airspace restrictions which were announced on 19 July 2011.

Since July 2011, the Government, with the assistance of the Civil Aviation Authority, have been preparing the necessary statutory instruments to give effect to the planned airspace restrictions. These detailed regulations have now been signed on behalf of the Secretary of State for Transport and will enter into force on 1 June 2012. NATS, the UK’s en-route air traffic service provider and publisher of the UK’s aeronautical information, will be publishing the details of these regulations on 17 May 2012 in its next aeronautical information circular. In addition, full details of the planned airspace restrictions, including maps, can be found on the airspace safety initiative website at www.airspacesafety.com/Olympics.

In total there are 15 sets of regulations, three covering the London area (a restricted zone for the main Olympics and prohibited zones for the Olympics and for the Paralympics), five covering the Olympic football tournament stadia at Old Trafford, Coventry, Newcastle, Glasgow, and Cardiff, and the remainder protecting the sailing venue at Weymouth, rowing at Egham and Eton Dorney, the road cycling events at Leatherhead and Brands Hatch, the canoeing events at the Lee Valley white water centre and the mountain bike racing at Hadleigh Farm in Essex.

Following extensive engagement with the aviation community, the regulations have been designed to minimise, where possible, their impact on aviation business, while ensuring the safety and security of the games. They also provide specific exemptions for aircraft such as those operated by the police or emergency medical services to enter the protected airspace, and for the Olympic Broadcasting Service to operate over the venues. We do not expect that any airports will need to close as a result of the planned measures, and there should be little or no impact on scheduled air services.

The Government’s paramount objective is the delivery of a safe and secure 2012 games for all, and the airspace restrictions will help to provide this whilst minimising the impact on the aviation community, so far as possible. However, the Government reserve the right to implement additional airspace security measures should the need arise.

Heathrow Airport (Operational Freedoms)

Tuesday 15th May 2012 Written Statements

[The Minister of State, Department for Transport (Mrs Theresa Villiers)]

My statement of 14 July 2011, Official Report, column 55WS, announced a phased trial of operational freedoms at Heathrow airport to gather evidence in relation to the greater use of tactical measures, in defined and limited circumstances, to prevent or mitigate disruption and to facilitate recovery. The trial is run by BAA, the airport operator, with oversight provided by the Civil Aviation Authority (CAA), the independent aviation regulator.

These measures are consistent with the Government’s commitment to runway alternation at Heathrow. I would also emphasise that the trial will not increase the number of flights at Heathrow which remains capped at current levels.

Phase one of the trial ran from 1 November 2011 until 29 February 2012. An interim report on the first two months of phase one was published by the CAA on 21 February 2012 . The CAA has today published its final report on phase one, alongside a report by BAA, assessing the impact on operations at the airport and on communities around Heathrow: www.caa.co.uk/apfg

The CAA’s report is encouraging about the benefits of the measures trialled so far, but suggests that more detailed data and analysis is required from phase two to draw definite conclusions on these and the impacts on local communities.

The CAA report concluded BAA ran phase one of the trial within the parameters agreed with Government and generally collected and published data for analysing the trial in an appropriate and transparent manner. The CAA noted that the broad spectrum of interested parties, and the technical nature of the measures trialled, made successful engagement with local communities challenging; and they made suggestions for improvement.

The report also accepted BAA’s analysis that phase one of the trial recorded:

dual arrivals were deployed for 3.2% of westerly arrivals at the airport (1,802 out of 56,260 arrivals); an average increase of 13 de-alternated flights each day on westerly arrivals, from 21 to 34 per day;

dual departures were deployed for 0.07% of westerly departures at the airport (38 out of 55,860 departures);

operational improvements in relation to arrival punctuality and delay, stacking (under specific circumstances) and taxi times following arrival;

A large increase in complaints, although it was not clear whether these were generated by the use of operational freedoms, as a proportion appear to correlate to a prolonged period of easterly operations which was due to weather conditions rather than the trial;

generally low awareness of the trial but some support for it from residents surveyed when its objectives were explained; and

no detriment to safety.

In my previous statement, I also set out the timetable for phase two of the trial. Following advice from the CAA, I am announcing today that I have agreed to a six month extension of phase two which will now run from July 2012 to March 2013.

The CAA concluded that the relatively short duration of phase one meant that the evidence it provided on the impact of operational freedoms was more limited than anticipated, partially as a result of an unusually high level of easterly operations. The extension until March 2013 will increase the amount of data generated enabling a more robust analysis of the benefits and impacts, allowing a direct comparison between phases one and two. A longer trial will also reduce the risk that external factors (such as easterly winds) significantly limit the amount of usable information. This will ensure that the eventual consultation with local communities on whether a more permanent operational freedoms regime is adopted at the airport is based on a sufficient level of evidence.

Phase two will also mean that Heathrow will benefit from greater resilience during the Olympic and Paralympic games period when the airport will be under more pressure than usual.

Improving punctuality, tackling delay and strengthening resilience at Heathrow would improve the quality of the UK’s international connections and enhance the reputation of our largest international gateway. Phase one has shown that, without prejudging our views on the associated impacts, there is potential to deliver operational benefits without increasing capacity. We therefore have grounds to believe that there is still more that can be done to deliver a better Heathrow, while continuing to protect communities affected by aircraft noise.

I have therefore agreed to the continuation of the trial of tactical use of dual arrivals and departures measures agreed for the first phase. I have also agreed that the following freedoms should be added to phase two:

Aircraft scheduled to arrive after 0600 will be permitted to land between 0530 and 0600 provided that the same number of flights scheduled to arrive between 0430 and 0500 are rescheduled to after 0500. This is expected to delay the onset of noise disturbance to local communities in the early morning period and enhance the resilience of the schedule;

During “segregated” operations departing aircraft may be re-directed (radar vectored) by air traffic control from their normal routes of departure (mostly within predetermined noise preferential routes). This is expected to improve the reliability of the schedule by increasing the departure rate from a single runway and improve the scope for reducing the number of unscheduled night flights;

Subject to approval of the safety case by CAA, it is intended to apply the same principles to enable dual departures later in phase two, but only within the predetermined noise preferential routes;

The cap on the more flexible use of dual arrivals allowed as part of the trial will be raised from 6 to 12 per hour;

The proactive tests used briefly in phase one will be continued. The periods during which these tests will be undertaken will be announced on BAA’s website during the first month of phase two.

BAA will shortly begin a further period of engagement with local authorities, communities and other stakeholders around the operation of phase two, particularly on the monitoring of noise impacts. Once the trial is complete, the evidence collected will provide the basis for a consultation with local communities. This will consider whether an operational freedoms regime of some form should be adopted on a more permanent basis at Heathrow and if so what safeguards should apply in relation to its use. This consultation will inform the subsequent decision by Ministers.

Employment Support

Tuesday 15th May 2012 Written Statements

[The Minister of State, Department for Work and Pensions (Chris Grayling)]

The DWP’s Work programme providers are required to ensure that stringent controls are in place to guard against fraud and to adhere to high standards of compliance in the operation of our contracts. By its innovative payment by results design, the Work programme also provides significantly greater protection against fraud than previous employment programmes.

In March 2012, against a background of public commentary on A4e, the Department was made aware of an allegation in respect of their separate mandatory work activity contract. This is very different from the Work programme. It is much smaller, shorter and focused on providing brief spells of work-related activity to individuals who will benefit from such activity. In contrast the Work programme aims to deliver sustained job outcomes for the long-term unemployed.

In the light of the allegation received, the Department announced it would audit its commercial relationships with A4e. The Department’s internal audit and investigations team undertook this audit, supported by Ernst and Young, and examined the controls operated by A4e on all its current contracts with DWP.

The audits for the Work programme, the new enterprise allowance programme and mandatory work activity are now complete. They have found no evidence of fraud in any of these contracts.

The original allegation suggested that A4e employees may have claimed payments for mandatory work activity participants who had not in fact been placed in work. The team investigated every MWA claim from the A4e office related to the specific allegation (Epsom) and a significant sample (20%) of all the other A4e claims under this contract. The sample evidence established that 97% of payments made related to a real participant who had been placed in a work-related activity. In the remaining 3% of cases, DWP investigators were nevertheless satisfied that the anomalies were attributable to inadequate procedures rather than fraud.

However, while the team found no evidence of fraud, it identified significant weaknesses in A4e’s internal controls on the mandatory work activity contract in the south-east. The documentation supporting payments was seriously inadequate, and in a small number the claim was erroneous. There was also a high incidence of non-compliance with other relevant guidance (including A4e’s own processes).

The process established prior to March fell significantly short of our expectations. As a result, the Department has concluded that continuing with this contract presents too great a risk and we have terminated the mandatory work activity contract with A4e for the south-east.

Contingency plans are in place to ensure there is continuity of support for participants in the mandatory work activity programme.

We have made clear to A4e that we continue to require the highest standards of governance in relation to all their other contracts. We are reminding all our other providers of their obligations and our requirements in this regard and, should any further allegations arise, we will examine the evidence thoroughly.

The Department will reflect on how it can further improve its processes in the light of these audits to address any remaining control risks across all contracts and providers.

Recent coverage has also prompted complaints about service levels on past employment programmes where, unlike the Work programme, the emphasis was on activities undertaken rather than on job outcomes. While this has not been part of our investigation, the Department is considering what further steps can best ensure that providers meet their minimum standards, and participants are clear about procedures for complaints.