National Minimum Wage (Workplace Internships) Bill

Debate between Alec Shelbrooke and David Nuttall

Friday 4th November 2016 Commons Chamber

[Mr Nuttall]

I fear that if the Bill becomes law there is a danger that what now appears to be the settled law as laid down by these cases will be thrown into doubt and there might be a whole raft of new cases with new definitions to be challenged in the courts. As I will say later, although this Bill refers to “employment practice”—a new term to me, which I will come on to—there is no clear definition, as far as I can see, of what is meant by that, and I anticipate it will have to be tested in the courts and in industrial tribunals.

Let me turn to the case of Hudson against TPG Web Publishing Ltd in 2011. It was also held in this case that the claimant was a worker. Keri Hudson worked eight hours a day between 10 am and 6 pm for a publishing company and supervised a team on a website. The employer had considered paying her but decided not to. The tribunal concluded that she was a worker with a contractual relationship existing between herself and the employer and was therefore entitled to be paid the minimum wage. The reneging on the payment was a key factor because it demonstrated that the respondent recognised that the position at least could be a paid position.

At that time the National Union of Journalists said of the judgment:

“This sends a clear message to media companies that if they treat interns like cheap labour, the NUJ will take you through the courts.”

It is clear from this case that the issue of interns who are actually carrying out work has been tested in industrial tribunals, which have found that if someone is working, they are liable to be paid. Unions have, to be fair to them, taken up this cause and are alert to the problem, and in appropriate instances take cases to a tribunal.

[Alec Shelbrooke]

I am listening carefully to my hon. Friend, and this draws into comments I made, as do his opening comments about the legalities around national minimum wage law. I said at the opening of my speech that we still have people not being paid when they should be. Does my hon. Friend feel that people have the courage to go forward, even with union backing, or might they be worried about the effect it could have on the future of that industry?

[Mr Nuttall]

I rather suspect that any individual who brings a case is more concerned about their own contractual position than the wider industry. They might be concerned about their position within the industry, and I wonder whether that is what my hon. Friend is driving at. But I imagine the industry would respect the judgments of tribunals and accept that an individual who had the confidence to challenge an employer on the interpretation of an Act of Parliament and was able to demonstrate to the satisfaction of the tribunal that they were on the right side of that would be someone employers should be looking to engage, because it would be someone who had the confidence, willingness and ability to take on a larger employer. If they manage to win that case, I would have thought that would only enhance their opportunity of being given a job.

--- Later in debate ---

[Alec Shelbrooke]

It is nice to think life should be like that, but I am not sure that it is like that.

[Mr Nuttall]

My hon. Friend is entitled to his view, but as a former employer myself that is the view I would take—although others might come to a different view.

In the Hudson case, as in the Vetta case, the tribunal determined that essentially this was not an internship, but was a job for which Ms Hudson should be paid, and it awarded her unpaid wages and holiday pay. I submit that on the basis of the findings in those cases the Bill offers nothing new to protect workers. If someone is actually working despite the fact that they might be called an intern, they are covered.

We should consider how many people would be covered by this Bill, even if it were to be of any value and brought into law. A written parliamentary question of 24 June this year by the hon. Member for Copeland (Mr Reed) asked the Business Secretary whether there were plans to gather data on the prevalence of paid and unpaid internships. At that time the then Skills Minister was my hon. Friend the Member for Grantham and Stamford (Nick Boles), and I am sure I speak for the whole House when I say we sincerely hope he is soon able to rejoin us in the House.

He replied:

“The Government has no current plans to quantify the number of paid and unpaid interns. There is no legal definition of an intern, but all those who qualify as ‘workers’ are entitled to the National Minimum Wage and National Living Wage.”

Let us reflect for a moment on why the Government were unable to provide a more specific answer to that relatively straightforward question. I submit that it would entail reporting by businesses, small and large, on the details of the thousands of interns who are employed in offices, shops and factories right across this country. Some companies would have hundreds in the course of a year and, given the nature of internships, which can often be for short periods of time—sometimes for a week or two weeks—can the House imagine the practical difficulties in trying to ascertain an accurate number?

In 2010, a briefing note on interns and the national minimum wage was sent to the then employment relations Minister, Ed Davey, and the then universities Minister, David Willetts. Sadly, that briefing note has been heavily redacted. I wish it had not been, because it would have been very interesting to read the whole document. Perhaps we could speculate about why it was so heavily redacted; the House will be pleased to know that I will not so speculate. The briefing note, which was released on 15 July 2010 following a freedom of information request, said:

“No single data source can provide an accurate estimate of the number of paid or unpaid internships. Unpaid workers are particularly hard to capture in national surveys as they are not on the PAYE system. Given the paucity of data, we have had to construct an estimate for the total number of interns based heavily on reports from the Chartered Institute of Personnel and Development (CIPD), combined with a number of other assumptions. This estimate is 50-70,000 internships, of which 10-15,000 are unpaid, but due to data limitations any figures should be treated as purely indicative.”

The Sutton Trust estimated in November 2014 that 31% of graduate interns in this country had reported working for no pay. Those data were based on the Higher Education Statistics Agency’s leavers survey of 2012-13. More recently, the Low Pay Commission said in spring this year regarding non-payment of the national minimum wage:

“This year we received fewer responses from stakeholders on this issue. While this in itself could be interpreted as evidence of an improving situation, the feedback we have received from stakeholders who have responded indicated that the issue remains live.”

To be fair, the report also referred to discussions with unions and expressed concerns about non-payment of the minimum wage in the arts and entertainment industry in particular. Clearly, however, there are real difficulties in quantifying the size of the problem. Although we do not know whether it is getting better or worse, if fewer stakeholders are contacting the Low Pay Commission about concerns over unpaid internships, maybe it is not such a critical concern to people.

My hon. Friend the Member for Elmet and Rothwell posted on his website a call for evidence from the people of Yorkshire who had had experiences of unpaid internships. In his brief opening remarks, he was unable to expand on the sort of response he had to that call for evidence. I commend him for doing his research, but it seems to me that it would have been better to ask for the evidence first and then try to look for a solution only if a problem could be identified. I am not convinced that the problem is exactly what my hon. Friend thinks it is. Even if there is a problem, I am absolutely certain that this Bill will not solve it. In my view, it will create more problems.

[Alec Shelbrooke]

To put my hon. Friend’s mind at rest, the problem was identified many years ago, and some of the examples that I received were used in my speech today.

[Mr Nuttall]

I am grateful for my hon. Friend’s report of that. I have been completely consistent in my approach to the proposed legislation. I voted against the previous Bill when it was put to a Division a couple of years ago, so he and I have both been consistent.

As it happens, I was an employer when the national minimum wage legislation was introduced. At the time, I suspect I was employing about 30 or 40 people, so I know from first-hand experience about the impact that it had, not just on me but on many of my clients, which were small businesses. It undoubtedly took up some staff time; it was new legislation and we had to look at how to comply with it. To be fair, although rogue employers will do all they can to break the rules—that will always be the case—the truth is that most businesses and most small employers bend over backwards to try to comply with laws that emanate from this place. Although some extra administration was involved, I do not want to over-egg the pudding; it did not take up a huge amount of time or dominate our practice, but we did have to deal with it.

The biggest problem was not so much the administration but the economic costs of the minimum wage. I refer not so much to those who were not covered by the legislation—in our small practice, perhaps only one or two employees felt any benefit initially from the imposition of the minimum wage—but to the knock-on effect that it had on wage differentials. That was the economic problem for small businesses. If, for example, the salary of the lowest-paid worker—say, the office junior—is increased to the same level as, say, the junior typists, they can legitimately and understandably claim that in order to restore the pay differential, they should have a pay increase. That has a knock-on effect on the next grade up, and so on. The ripple effect of increasing the wages at one level can soon be felt much higher up the pay grade.

Turning to the engagement of additional staff, the fact is that if an employer has work that needs doing, they will engage a new member of staff. That may be part-time, of course—there might not be enough work to fill a full-time role, but the employer will engage either a part-time or full-time staff member. I accept that there might be unscrupulous employers who, seeing a short-term amount of work that needs doing, might seek to engage an unpaid intern to do that work. As I demonstrated earlier, however, my view—which, to be fair, is backed up by cases—is that that situation would already be covered if the person involved could demonstrate that they were carrying out work and were entitled to be paid the national minimum wage. So who would be covered by my hon. Friend’s Bill? People who are doing work are already covered, so the only other people who could be covered are those who are not working: the ones who are watching. Is my hon. Friend really suggesting that the national minimum wage should be paid to people who are simply watching someone else work?

I shall let hon. Members into a little secret. What goes on in this Chamber might be considered a spectator sport, and quite rightly, but I take the view that running a small business is not. When I was running a small business, I could not afford to pay people to come and watch me work. I did not mind paying them if they were carrying out work, but I could not afford to pay them simply to come and watch. I did not mind them coming to do work experience, and I got lots of requests—I still do, as a Member of Parliament—from people asking to come and spend time with me. I said, “Of course, there’s no problem. I will chat to you and I will give you advice.” But I could not pay them to do that. The reality is that an employer, and particularly a small business, cannot afford to pay people who want to sit and watch and then simply walk away having added no value whatever to the business.

Let us ask ourselves what determines a wage on the open market. It is an essential truth that work should be compensated according to productivity. A wage is the price at which a worker is prepared to sell his or her labour; the wage is the balance between what the employer is prepared to pay and at what level the labourer is prepared to sell. The employer will of course take into account the productivity of the labourer, and the labourer will consider how much they value themselves working for that employer. They will also take into account the experience of working there and the working environment. Someone who is prepared to spend time going on work experience—or an unpaid internship, if that is what we want to call it—is demonstrating that they value the experience of just being there and the contacts that they will make while they are there. In their eyes, those considerations cancel out the need for any monetary compensation. I believe that it is absolutely right that an individual should be free to decide for themselves the value of their own labour.

So what would happen if that basic arrangement were interfered with? What would happen if the law said—as I believe would be the case if the Bill became law—that an employer would have to pay to be watched? The obvious conclusion is that a black market would develop, as happens in any market where the price of a product or commodity is set at an artificially high level, higher than the genuine market level. If someone wants to do a few weeks’ work experience—whether it is called an internship or not—without being paid, the law should not prevent that from happening.

Let me deal briefly with the claim that unscrupulous employers are somehow exploiting a loophole. It seems to me that there is much more likelihood of an unscrupulous employer exploiting an individual who is being paid, because they will then expect a return on their payment. If someone is not being paid at all, it is surely far more difficult to exploit them and far more likely that that intern doing work experience would simply walk away.



I want to look in detail at the problems in the Bill. The first problem revolves around the definition in clause 1, which states:

“For the purposes of this Act, a workplace internship is an employment practice in which a person (“the intern”)—

undertakes regular work or provides regular services in the United Kingdom for—

(i) another person;

(ii) a company;

(iii) a limited liability partnership; or

(iv) a public authority; and”.

At the moment, the word “intern” has no legal definition. The official Government website, gov.uk, states:

“Internships are sometimes understood to be positions requiring a higher level of qualification than other forms of work experience, and are associated with gaining experience for a professional career.”

The key term in clause 1 is “employment practice”. Those two words are central to what I would call the obfuscation at the heart of the Bill. What is an employment practice? I venture to suggest that it is actually an employment contract. In other words, this clause is attempting to cover every employment contract in just about every conceivable working environment. Perhaps my hon. Friend would agree, and say that that is exactly what he is trying to do. Perhaps he is trying to make this so watertight and all-encompassing that absolutely no one could escape from it, but let us consider for a moment the problems that could arise from that.

Let us take the example of someone who is setting up a gardening business and regularly volunteering their time to maintain the garden of, say, an elderly neighbour. For the gardener, who wants to work, this is an opportunity not only to help the neighbour but to demonstrate to the neighbourhood that they are capable of the job, which could lead to paid work. Clause 1(b) states:

“(b) the purpose of the employment practice is—

(i) that the intern meets learning objectives or gains experience of working for the employer listed in section 1(a); and

(ii) to provide practical experience in an occupation or profession.”

We know from clause 1(a) that the intern could be working for a sole individual, which would cover the example of someone wanting to work for their neighbour. In that scenario, could the neighbour become liable to pay the national minimum wage? To me, that seems very likely. I submit that that would be an unintended consequence that could result in a financial cost when the person was simply trying to do someone a favour.

Nowhere in the Bill is there a definition of regular work or regular services, a point made earlier by my hon. Friend the Member for Shipley. While we are fortunate that the Bill comes with some explanatory notes, they do not give any further clues as to what actually amounts to regular work or regular services. When something is not specifically defined, there is the potential, as pointed out by my hon. Friend the Member for Rugby (Mark Pawsey) in an earlier intervention, not only for further references being necessary in order for an industrial tribunal to clarify the situation, but for terms to be widely construed. If someone is called in to do some filing in an office every Tuesday, is that regular? If a volunteer assists with a monthly live event, is that regular? It clearly means that something happens more than once, but there is no clear guidance.

I suspect that what would happen with the Bill is that the term “internship”, which has been adopted and is widely used and which this Bill seeks to outlaw, will be rapidly replaced by another term. People will try to get around the legislation by using another term—perhaps “work shadowing”. It may be that work shadowing is already covered by the Bill—we would have to see—but if someone has not been promised future work, that situation could be caught by the Bill. I would therefore submit that the Bill’s scope is too wide.

Clause 3 attempts to narrow that scope by setting out some exclusions. It excludes students who are required to do work experience as part of their course. In other words, the Bill recognises that work experience, when part of a wider course of study, does not have to be paid. To be fair, my hon. Friend the Member for Elmet and Rothwell touched on that in his remarks, but I did not intervene because he made it clear that he was not going to take any more interventions. However, the Bill’s true effect will be to discriminate against precisely those who have been told this morning that it seeks to help. If someone is lucky enough to go to college or university, the Bill says that it is fine for them to go on a placement or have 12 months’ work experience. If someone is not that lucky and just wants the opportunity to see what workplace life is like, the Bill states that an employer must pay them. That cannot be right. I am unsure whether that has been thought through by the Bill’s promoter, but it seems that that is exactly what would happen if the Bill became law.

The Bill also excludes those “of compulsory school age”, who are excluded from the National Minimum Wage Act 1998 anyway; those who are doing apprenticeships; and those otherwise excluded under devolved powers. However, I now want to comment on clause 3(1)(d). Clause 3 states:

“For the purposes of this Act, section 2 shall not apply if the person is—

(a) a student at a higher or further education institution…

(b) of compulsory school age;

(c) undertaking an approved English apprenticeship…

(d) meets the terms of a definition set out in regulations made by the Secretary of State or, as the case may be, the relevant Scottish, Welsh or Northern Ireland Ministers.”

Taken together, those words state that

“section 2 shall not apply if the person is-

… meets the terms of a definition”.

I gently suggest to my hon. Friend that there must be some words missing from clause 3(1)(d)—probably “someone who”. I think it should say that section 2 “shall not apply if the person is—someone who meets the terms of a definition”. It does not make sense as it stands.

The clause also runs the risk of different regulations being made in different parts of this United Kingdom. I hope that my hon. Friend will say that I have missed something and that that is not the case, but the clause seems to suggest that if regulations are made by the Secretary of State in this place or by relevant Ministers in the devolved Administrations, different classes of people would be excluded in different parts of the United Kingdom. Is that the case? Perhaps my hon. Friend will reflect on that and comment on it when he winds up.

I am conscious of the fact that many other Members wish to speak , but I want to talk about the many other people who have looked into this problem. In 2011, the policy group Perspective produced a paper called “Arguing for the introduction of paid internships”, detailing international comparisons of the action taken on this issue. It referred to the 2010 report from the International Labour Office “Global Employment Trends for Youth”, which looked at international comparisons. I do not know whether my hon. Friend, in drawing up the Bill, has examined the situation in other countries and whether the problem he has identified has been solved anywhere else in the world—it may well have been. Some countries, such as Canada and South Korea, have committed to funding internships in key sectors, which may be one way of doing this; we could simply throw Government money at it and say, “We will pay for people who need work experience.” South Korea extended its state-supported youth internship programme and introduced wage subsidies for small and medium-sized enterprises that engaged interns on regular contracts at the conclusion of their internship. I would not want to go down that road, but it has happened in other countries.

More interestingly, the Institute of Economic Affairs, perhaps spurred into action by the publication of my hon. Friend’s Bill, published a discussion paper in August entitled “And how much do you earn?”. One of its conclusions was that the current minimum wage legislation “should be simplified”, and I strongly support that. If this Bill were to be amended in Committee and to go down that road, there would be a lot of merit in that approach. The authors of that paper, Ryan Bourne and J. R. Shackleton, acknowledged that the national minimum wage has “broad public support”, but they said that

“the introduction of the National Living Wage threatens to lead to a populist arms race in terms of statutory minimum pay rates.”

The paper made a number of suggestions, including reducing the number of bands to just two, one for people 18 and over and the other for people 25 and over. It also suggested that the Government should:

“re-emphasise the independence of the Low Pay Commission, allowing it to continue to recommend changes to both rates in the new system according to the best evidence available on the pay-employment trade-off. This is particularly important given the pressure there will be to continue increasing wage rates even in economic recessions.”

In conclusion, the website Simple Politics calls this Bill “The ‘pay interns’ Bill”. I would argue that on closer inspection it is not that, but “The making work experience unaffordable Bill”. Even worse, it could be called “The denying young people opportunities Bill”. The growth in the number of unpaid internships has arisen as a consequence of the minimum wage legislation. I said earlier that I had not previously come across the term “internship”; it has arisen only since the arrival on the scene of the minimum wage, and with it has come the problem of elevating people who are doing work experience to the status of workers.

It was never the intention—the Minister actually said this, in terms—that businesses would have to pay wages to people who were not actually working, but simply experiencing the workplace. The most likely result, if the Bill became law, would be a reduction in the number of opportunities available to young people. Why? Perhaps because the law recognises that work placements do not have the same status as actual work. If an intern is actually working, it is already illegal not to pay them the national minimum wage; that is in the national minimum wage legislation, which Her Majesty’s Revenue and Customs is enforcing. The Bill is simply unnecessary.

National Minimum Wage (Workplace Internships) Bill

Debate between Alec Shelbrooke and David Nuttall

Friday 4th November 2016 Commons Chamber

[Alec Shelbrooke]

I am most grateful to my hon. Friend, who has pre-empted another section of my speech. If he will bear with me, I will address that issue specifically.

[Mr David Nuttall (Bury North) (Con)]

My hon. Friend the Member for North East Somerset (Mr Rees-Mogg) may well have pre-empted another section of the speech, but I hope that when my hon. Friend the Member for Elmet and Rothwell (Alec Shelbrooke) gets to it he will set out where the Bill makes any reference to volunteers, as that is what matters.

[Alec Shelbrooke]

I can answer that now. If my hon. Friend looks at clause 1, he will see that it defines what the internship is, not what it excludes. I will come on to deal with that in more detail.

[Mr Nuttall]

rose—

[Alec Shelbrooke]

If I may, I will elaborate on my argument and then come back to my hon. Friend.

We are dealing with the exploitation of volunteers. This Bill does not concern itself with those who donate their spare time to support charities, for example, in helping to raise funds or deliver social activities. Those activities are a world away from interns being asked to work five days a week for long periods of time. Clause 1 defines what a workplace internship is, and it will ensure that those who undertake regular work and services will be paid the national minimum wage in return for their labour. The clause will close a loophole in minimum wage legislation.

--- Later in debate ---

[Alec Shelbrooke]

My hon. Friend used the term “work experience”; I will come on to that later. The direct answer to his question is yes, I would rather that this form of contract did not exist; I would rather that there was no need for it to exist, and that things moved on.

[Mr Nuttall]

The Independent Parliamentary Standards Authority, which we have to deal with daily, has its own model intern agreement. Has my hon. Friend had the opportunity to compare the terms of its agreement with the one to which he referred?

[Alec Shelbrooke]

I am most grateful to my hon. Friend; I must admit that I have not looked into that. Perhaps he would like to elaborate on that later, when he comes to speak—at length, I am sure.

As I said at the start of my speech, this practice takes place in the House, and that sends the message to businesses across the country that we think that it is acceptable. I do not think it is, which is why I introduced the Bill. The broader societal issue is that interning is becoming a prerequisite for graduates looking to access their chosen profession. As was reported by the Social Mobility Commission, over 30% of newly hired graduates had previously interned for their employer. That rises to 50% in some sectors. According to the Sutton Trust, 31% of graduate interns are unpaid. Most of them are unable to claim jobseeker’s allowance or universal credit, as they are unable to accept offers of work by virtue of their internship.

That point about the ability to claim welfare is important and goes to the heart of the problem. The IoD’s model internship agreement establishes that companies expect their interns to be present during office hours; how can interns then be expected to look for work, let alone attend interviews? Although legally and technically an intern is able to leave, in reality the threat of a poor reference or the perception that leaving would create a bad impression and lead to the intern not being hired by the company at the end of the internship make that worthless. Even those who go on to work for a company are often unwilling to speak out, for obvious reasons, but when young people have taken employers to employment tribunals they have been successful: companies such as Sony and Harrods have been required to pay their former interns’ unpaid wages. However, is it right that the issue should have to go before an employment tribunal before people are paid?

I would describe myself as a trade unionist. Indeed, I was a member of the Unite union before it became more interested in internal Labour party politics than representing the interests of working people. The ordinary man or woman in the workplace is the reason I believe that representation is vital. We forget that a lot of people do not have the courage to put their head above the parapet. They may well fear for their livelihood and not want to be a target.

--- Later in debate ---

[Alec Shelbrooke]

The important distinction that needs to be drawn is that we are talking about deliberate, advertised, unpaid internships. My hon. Friend the Member for Shipley (Philip Davies) made an important distinction between people who come along, volunteer and want to work, and people who advertise for somebody to come and work for them for six months. When we see the perversion of the two words put together—“advertising” for “volunteers” to come and work—it is a bit like saying, “You need to go on a suicide mission, men. Who will volunteer?” and then telling them, “You’ve volunteered.” That makes a mockery of things.

I want the Bill to really bring these issues to the fore. I have heard the interventions from my hon. Friends, and some very reasonable points have been made, but that does not mean that we should turn away from doing anything, and I hope the Bill will start us on the route of trying to address this issue.

[Mr Nuttall]

If my hon. Friend’s concern is the advertising of these positions, why is that not mentioned anywhere in the Bill?

[Alec Shelbrooke]

The Bill refers to exclusions—people who are on internships that are part of an accredited degree course and who are “of compulsory school age”—and to employers not making national insurance contributions. That shows that a system is being developed whereby there are exemptions to the Bill, and there are opportunities for people to come along and do exactly the things outlined by my hon. Friend, but that does not mean that this should be a catch-all for everybody. Having been able to put those exclusions in place, we should be able to move things forward.

My hon. Friend the Member for North East Somerset (Mr Rees-Mogg) asked me very specifically why a period of 28 days was not included. As I said, that was my initial intention, but the legal arguments I have heard say that that approach was full of just as many loopholes. I very much hope that more learned colleagues than I may be able to explore those arguments further today. That could be taken on in Committee.

--- Later in debate ---

[Mr Nuttall]

I am extremely grateful to my hon. Friend for that intervention and I think that I need to go for those lessons, too, because I always dread having to follow the hon. Gentleman in case I am asked to pronounce his constituency. I think that I need to sign up for that course.

I congratulate my hon. Friend the Member for Elmet and Rothwell (Alec Shelbrooke) on presenting this Bill this morning and on coming third in the ballot for private Members’ Bills. As he made clear when he introduced the Bill, and to be fair to him, he has spent years campaigning on this issue; I think that is fair to say. That in itself demonstrates his determination on this issue and I know that he is introducing the Bill with the very best of intentions. He listed this cause as one of the six points in the plan that he put before his own electorate, so I do not criticise him in any way for introducing the Bill.

To be honest, I agree with my hon. Friend on the other five points that he put forward: focusing on jobs, action on dementia, supporting schools, calling for affordable family homes and tackling crime. Unfortunately, I have to say very gently to him that I do not support the Bill, and I will set out why. I hope that he will accept that I do so in a spirit of helpfulness.

[Alec Shelbrooke]

I am genuinely pleased at the number of my colleagues who are here today, perhaps to argue against the Bill, but this is a subject that, step by step, I have pushed further up the agenda and there are many issues to be explored. I say in all honesty and in all integrity that I sit here today to hear the points that he has to make, and I will listen very carefully to what he has to say.

[Mr Nuttall]

I am very honoured to hear that; to be perfectly honest, I am humbled to hear it, because I am not sure that my speech is worthy of that. Perhaps I have gleaned one or two things from looking at my hon. Friend’s Bill that will genuinely help. I will certainly be able to draw his attention to one or two details, which will assist him.

Universal Credit: North-West

Debate between Alec Shelbrooke and David Nuttall

Wednesday 13th January 2016 Westminster Hall

[Alec Shelbrooke]

If I was allowed to, I would.

[Mr David Nuttall (in the Chair)]

Order.