Football Governance Bill [HL]

Baroness Grey-Thompson Excerpts

2nd reading
Wednesday 13th November 2024 Lords Chamber

[Baroness Grey-Thompson (CB)]

My Lords, I draw noble Lords’ attention to my entry in the register of interests. I am chair of Sport Wales, I sit on UK Sport, I am a trustee of the Foundation of Light and I authored the independent Duty of Care in Sport review in 2017, which was requested by the then Sport Minister, Dame Tracey Crouch. I thank the many organisations that have been open and generous with their time in preparing for today’s debate.

Dame Tracey’s fan-led review demonstrated that self-regulation in football has failed, and the creation of an independent football regulator could strengthen the game that so many cherish. As we all know, football is deeply woven into our country’s cultural fabric. At its best, it provides incredible social value, health benefits and entertainment to many communities across the UK, as well as an important revenue stream into the UK economy. Therefore, the sustainability of football for years to come is important.

While an EDI strategy is included in the Bill, there is an obvious exclusion: the women’s game. I understand that many noble friends might suggest that adding the women’s game to the Bill would create another complex layer, but I think we should be open about what we are talking about today. It is a men’s football regulator, not one for the game of football.

I have been told that the women’s game needs a chance to self-regulate and that an independent football regulator might stifle investment opportunities that could become available to women’s football in the future, but I disagree. The fan-led review concluded that:

“Fair distributions are vital to the long term health of football. The Premier League should guarantee its support to the pyramid and make additional, proportionate contributions to further support football”.


If the aim of the Bill is to ensure financial sustainability for the future of football, should that not be for the whole game?

The women’s game is still connected to men’s football in many cases. Sadly, there are very few examples of independent women’s football clubs like the London City Lionesses, although we are slowly seeing more investment in women’s football. Many will say that no regulator is required, but I believe the exclusion of the women’s game from the Bill could hinder its growth so that it continues to be an afterthought when it should be at the forefront of football’s innovation.

Would it not be beneficial for the women’s game to avoid the fate that we have seen in the men’s game and to take proactive steps to ensure that the women’s game is protected from the same misconduct? Oversight and focus could ensure that the women’s game raises governance code standards in performance, medical and welfare provisions to drive positive change for the whole game so that football players could receive the duty of care that they deserve.

I intend to table amendments that would cover corporate responsibility and would require a club to consider the impact of the club’s operations and activities on society and the environment, in particular taking reasonable steps to increase diversity and inclusion of underrepresented groups; to eliminate discrimination; to have a positive impact on the community; and to establish, and keep updated, a target consistent with corporate governance best practice in respect of the gender diversity of officers.

In a survey by Women in Football in 2024, only 21% of women who responded said they felt supported to forge a path to the top, while 89% of women who responded had experienced gender discrimination in the football workforce. Systematic change is needed to accelerate progress, taking pockets of good practice and scaling the impact of gender diversity leadership across the professional game.

Any new regulator needs to have the voices of the players included. I urge His Majesty’s Government to ensure that appropriate consideration is given to the Professional Footballers’ Association as well as to the experience and knowledge of women in football. My work on the duty of care in sport has been across many sports, both amateur and professional, and the voice of participants enhances the outcomes that we would all like to see, so it is important that any fan consultation does not just become a tick-box exercise.

With my Welsh hat on, I understand that representatives from the Welsh Government have met colleagues from DCMS on the Bill. It was agreed that the Bill impacts Wales only in relation to those clubs that play in the English football pyramid, not Welsh football in its wider sense, so I wonder whether the Minister can say whether there is a need to include or add the regulator to the Senedd Cymru (Disqualification) Order 2020. As I understand it, it is an order of the Privy Council, but clarification on that matter would be helpful.

Football Governance Bill [HL]

Baroness Grey-Thompson Excerpts

Committee stage
Monday 2nd December 2024 Lords Chamber

[Baroness Taylor of Bolton (Lab)]

My Lords, the noble Lord, Lord Addington, makes a good point about football clubs needing to be outgoing and outward looking, able to offer advice to other charities or organisations locally and to encourage football. The vast majority of clubs do that. Perhaps there is insufficient evidence about best practice or not enough sharing of it, but the vast majority of clubs have a good outreach programme, and that is much valued by local communities.

I rise to say a few words about Amendments 151 and 165, which are about the corporate responsibility of clubs in general. The noble Lord touched on some ways in which they can have an impact. We have just talked about the environmental sustainability that is necessary, and the Minister has given reassurances on that point.

I want to mention, in particular, the need for football clubs to increase diversity, include underrepresented groups and eliminate discrimination, which I am afraid exists in many areas of business, from boardrooms to employment records. Local football clubs have a big impact on their community and can lead the way in showing what can and should be done. We need to know what is happening in our clubs, and therefore a reporting mechanism on these areas would be important and of assistance.

We have seen some changes, for example, in the gender diversity of people employed by football clubs. We see many more women taking up roles, but there is a long way to go. It would be good if we could encourage better governance at football club level on all these issues. I agree with what has been said about not having mission creep, and some of these areas are covered by parts of employment law, for example, but we have to look to the long term to improve the good governance of football clubs. Yes, we can encourage best practice, as the Minister said earlier, but there is more to do.

[Baroness Grey-Thompson (CB)]

My Lords, I speak to Amendment 165 to which my name is attached. I declare my interests; I am chair of Sport Wales, I sit on UK Sport and I am a trustee of the Foundation of Light.

I start by thanking the Minister for answering my question from Second Reading on what would happen between the Privy Council and Senedd regulations with this Bill. I am not a season ticket holder, although I do spend a lot of time watching the Welsh women’s football team—good luck to them tomorrow night—and Thornaby FC women’s team.

Like the noble Lord, Lord Addington, I believe in the power of football to change lives. I realise that most of the amendments that I have my name to in this Bill will be considered out of scope, but I do share the noble Lord’s concern over academies. My 2017 duty of care report, commissioned by the then Sports Minister Tracey Crouch, has some answers on that which have not yet been taken up.

This is important in relation to understanding the communities of which football clubs are part. We have talked a lot about the big clubs tonight. Thornaby Football Club, which is very low down in the leagues, decided earlier this year to cancel the women’s and girls’ team. The community came together, people stepped in—partly due to the Women’s Sport Collective—and the team was saved.

This, to me, is the power of football at its best. There is a lovely interview online with a young girl called Lily, aged seven, who was asked what she thought about women’s football being cancelled. She indignantly said, “If girls want to play football, you can’t just not let them”. For me, the impact that these amendments would have all through the game is important; it sets an important tone.

In the original review, Dame Tracey Crouch said that equality standards were a non-negotiable part of the regulator. We have seen this in other sports. The code for sports governance, launched in 2016 by the sports councils, which covers over 4,000 organisations, has made a materially positive impact on the world of sport.

I believe that club governance should include these equality standards, because they link back to accountability and integrity. I can speak only for the Foundation of Light. I am biased, but it runs incredible programmes in communities as lots of foundations do. We are lucky that we have a good link to, and support from, the club. The aim of the foundation is to involve, educate and bring people together through football in Sunderland, south Tyneside and County Durham, and to improve education, health and well-being

This has a significant impact on the community. It is important that we can measure this impact in relation to the community it represents, to help develop and refine these programmes and get to those who they can have the most impact on. This is an important part of what we should be looking for in relation to football, to be able to make a real difference at the grass-roots level.

[Baroness Brady (Con)]

My Lords, I rise to speak against this set of amendments, which would add corporate responsibility requirements to the Bill. Before I do so, I want to say how much I respect and understand where the noble Lord, Lord Addington, is coming from. As a shareholder in the Premier League, I commit to him that we will meet with him to think about ways in which we can work together to deliver some of the aims that he spoke so passionately about, because we are all in agreement that they are important.

I want to make sure there is no misunderstanding in this House of the extraordinary social impact that football clubs already have in their communities and what drives this activity. Let me share some perspective on what football clubs already deliver. The Premier League provides over £500 million annually to support lower league clubs, fund youth development and invest in community facilities. We support every single football league club to provide its own community programmes, too. This is not a peripheral activity; it represents the most comprehensive community investment of any business sector in Britain. I cannot think of any other sector that voluntarily shares such a huge proportion—over 16%—of its central revenues in such a way.

The Premier League Charitable Fund’s £110 million three-year budget supports half a million people annually through targeted community programmes. Significantly, 45% of this activity takes place in our country’s most deprived communities. This April, the Premier League announced additional funding of £33 million per season from 2025-26 to further enhance this work.

The scale of impact that this work has is remarkable. Through the Football Foundation, Premier League funding has enabled over 70,000 grants to improve grass-roots facilities, supporting nearly 70,000 community teams last season alone. The Premier League Primary Stars programme reaches 84% of primary schools across England and Wales; that is 19,000 schools and over 18 million student interactions since 2017.

These are not isolated initiatives. More than 100 club-connected charities work daily in their communities. Programmes such as Premier League Kicks create opportunities for young people at risk of anti-social behaviour. Premier League Inspires develops personal skills and positive attitudes in young people aged 11 to 25. This work touches every aspect of community development.

Football has naturally evolved its social contribution without regulatory compulsion or diktats. What other business sector can demonstrate this level of sustained community investment? What other industry has built social responsibility so fundamentally into its operating model? Premier League clubs—indeed, all football clubs—understand their role as community institutions and deliver accordingly.

The Bill’s purpose is to address specific issues around what I think the Government mean by financial sustainability and governance. Adding layers of corporate responsibility requirements would not only duplicate existing good work but risk distracting the regulator from its core purpose. We have seen in other sectors how regulatory mission creep can undermine effectiveness. We must not let that happen here again.

Football clubs are not just businesses that happen to do some good work in their communities. They are the beating heart of those communities, woven into their very fabric across generations. When a child steps on to a Premier League-funded pitch in a deprived area, when a struggling student finds inspiration through Premier League Inspires, and when a disabled young person discovers the joy of playing football through a club foundation, these moments represent something profound about football’s role in our society.

Premier League clubs understand their power and their responsibility deeply. They live it every day through their actions, their investment and their commitment to their communities. I do not believe any regulation could ever mandate or compel this level of social impact; it comes from an authentic and deeply felt understanding of football’s unique place in our national life.

Let us keep the regulator focused on its vital purpose and trust instead in football’s consistent commitment to social good: not because rules demand it but because it is already so fundamental to what makes English football so special.

Football Governance Bill [HL]

Baroness Grey-Thompson Excerpts

Committee stage
Monday 9th December 2024 Lords Chamber

[Lord Markham (Con)]

I would like to support absolutely these amendments. I say for the record—and I am sure that I speak for all contributors to these debates—that I am making these points because I care deeply about football and about what is best for football. I think these amendments absolutely do that.

I have many examples of sitting on boards as an independent non-exec director; they are absolutely the sort of people we want, making sure that a club is putting forward appropriate business plans that are sensible, and sometimes taking a risk—risk appetite is in these amendments—but with the right approach to doing so. Having that balance on the board, of owners, supporters and independent, wise heads, has got to be a sensible thing. With that in mind, I offer my support for the amendments.

[Baroness Grey-Thompson (CB)]

My Lords, I rise very briefly to speak to Amendments 54, 156 and 157. I apologise to your Lordships for not being here on the previous day of Committee but, as chair of Sport Wales—I declare my interest—I was chairing a meeting of Welsh governing bodies of sport.

In my time involved in sport, I have sat on a number of different sports bodies, including British Athletics, where intimate knowledge of the sport is really helpful, and the Olympic Park London Legacy Development Corporation, where wider knowledge of a range of sports makes a difference. I put my name on these amendments because I sat for two years on the board of Yorkshire County Cricket Club and was interim chair for nine months. As part of that, I was challenged occasionally on whether I knew the laws of cricket and how dare I put my name forward for this. But I was not there as an independent non-executive to umpire a game; I was there to bring good governance to the county.

Bringing that jigsaw of skills is really important. As the noble Lord, Lord Knight, mentioned, there is a sports governance code. Olympic and Paralympic sport have benefited greatly from having this. It is about bringing that expertise, accountability and scrutiny. For me, it is about setting the tone for the whole pyramid of the game, and how that feeds up to the Premier League. If we do not get this right for the pyramid, we do not get it right for the sport. I look forward to hearing the Minister’s response to these amendments.

[Lord Reay (Con)]

My Lords, I wish to speak briefly to Amendment 249, laid down by the noble Lord, Lord Mann, and Amendment 156 from the noble Lord, Lord Bassam. Regrettably, I was not able to participate at Second Reading, for which I apologise. I declare an interest as an enthusiastic football fan and supporter of West Ham United since the days of Bobby Moore and Geoff Hurst—which dates me a bit.

Clause 20 of this Bill introduces corporate governance duties with regard to equality, diversity and inclusion. Amendment 249 from the noble Lord, Lord Mann, would create an additional duty on football clubs to produce an annual report detailing the club’s diversity and inclusion strategy. This sounds in theory like a good thing. The problem here is that the Football Association’s idea of diversity and inclusion seems to be to promote some forms of diversity while silencing—even excluding—others.

The current approach at the FA punishes and excludes one particular group: women who object to male inclusion in the women’s game. Noble Lords have previously spoken in this House about the 17 year-old girl who was disciplined and suspended for asking a male player on the pitch in a women’s game, “Are you a bloke—a male player in a women’s game?” She was suspended. That is not inclusion.

Amendment 156, in the name of the noble Lord, Lord Bassam, proposes that the corporate government statement must include a club’s plan to improve the diversity of season ticket holders, staff and senior managers. The FA’s investigations unit helped Newcastle United Football Club collect personal information about a lesbian fan which resulted in her suspension by the club from attending matches because someone at her club did not like her social media posts. This behaviour by the FA and the club is not inclusion.

Both examples show intolerance of what are called gender-critical views—that is, the ordinary scientific and common-sense understanding that there are two sexes, that human beings cannot change sex and that sex matters. Those are mainstream views and they are critical to ensuring fairness and safety in sport. People who hold and express them are protected against discrimination and harassment on the basis of belief by the Equality Act 2010, but the FA is punishing female players and fans for expressing these views.

Through its partnership with Stonewall, the FA has made its campaign one of intolerance, disallowing the expression of any views other than the mantra of “trans women are women”. When diversity and inclusion is defined by more tolerance, I shall welcome it. If we compel English football to pursue more of this so-called diversity and inclusion, it will be at the further expense of women and girls.

What is the solution? The solution is to stop talking in vague terms about diversity and inclusion and have the courage to talk about the groups who need to be included: women and girls, gay men and those who are disabled. Let us have less of the thought-policing and more genuine inclusion. Until we can do that, we must oppose the further imposition of vague diversity and inclusion requirements, because they are anything but inclusive.

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[Baroness Taylor of Bolton (Lab)]

My Lords, I will say just a word, because Amendment 72 in my name and that of the noble Baroness, Lady Grey-Thompson, is included in this group. We have, to a certain extent, discussed this already, because this reflects on the kind of support that clubs would get were they to seek a licence, get a provisional licence or try to comply with the regulations that will be there. The Minister was very reassuring when we discussed this previously, but I hope that, at some stage during the passage of the Bill through either House, we can get a little more detail on how this may work in practice.

[Baroness Grey-Thompson (CB)]

My Lords, I have put my name to Amendment 72, but shall comment briefly on the amendments in the names of the noble Lords, Lord Mann and Lord Addington.

We need to be clear that this is a regulator for the men’s game, not the game of football. I am really excited to see the growth of women’s football; it has a massive impact on society. Some 80% of women are not fit enough to be healthy, and football is one of those sports that connects and is changing the relationship between girls and physical activity and sport. I was at the Wales v Northern Ireland women’s game the other week and the groups of teenage girls coming to support in a way that they might not support the men’s game, and the little girls dressed in their Welsh kit and goalkeeper’s kit, was a really beautiful sight to see.

But the women’s game needs to be protected and nurtured, and I do not want to see any unintended consequences of regulation or anything that makes it harder for women to be involved in what is an incredible game. I am meeting the Minister this week, and this is one of things I will be discussing with her.

[Lord Goddard of Stockport (LD)]

My Lords, I will be very brief. In my view, these are proper probing amendments about unintended consequences—such as with Solihull—and the need to support women to get to the elite level, as well as the points made by the noble Baroness, Lady Grey-Thompson. This is not about having an argument or asking the Government to rethink anything; these are truly probing amendments asking the Minister and those who work on the Bill to look at these points and make the Bill better. I am so thankful for the support of the noble Lord, Lord Markham, in that. This group gets to the nub of an issue that can be dealt with very quickly.

Football Governance Bill [HL]

Baroness Grey-Thompson Excerpts

Committee stage
Monday 16th December 2024 Lords Chamber

[Lord Addington (LD)]

My Lords, it might be convenient for me to say a few words on this. Primarily, I am drawn to the amendment from the noble Lord, Lord Bassam, for the reasons he gave. We have heard that this is a wonderful, successful league. Bits of it are but, unfortunately, those are the bits at the top. Most of the cultural capital, I am afraid, is in the less glamorous clubs with less successful balance sheets.

We have a situation where we want to maintain the whole of the football structure: five leagues. This has proven to have—let us say—attracted financial irregularity; I think it was described as “chancers and fantasists”. We have to do something to stop this or we will start to have more disasters that mean something to the fan base.

The amendment from the noble Lord, Lord Bassam, starts to address this. I hope that the Government are far more in tune with that amendment than with some of the others in this group.

[Baroness Grey-Thompson (CB)]

My Lords, I rise briefly to speak to Amendment 128. We are getting to the crux of what this regulator should be about: making sure that there are sensible financial decisions, and that risks are mitigated so that they do not jeopardise clubs’ futures.

Clubs in the EFL are expected to lose around £450 million this season and are reliant on owners to fund the shortfall. If this funding is not forthcoming, it can lead to financial trauma. Only 66 of the 92 clubs that filed accounts for the 2021-22 season included data on wages and cash reserves. Nottingham Forest spent £58,606,000 on wages but had just £25,000 in cash reserves—five hours’ worth of reserves. Surely that cannot be acceptable.

[Lord Moynihan (Con)]

My Lords, I will speak to the amendments standing in my name in this group. I apologise to my noble friend Lord Maude if I address some of the plethora of regulations, conditions and verbiage concerned. I am proposing a number of amendments that I hope will facilitate and ease the position that the Government face in this context.

I turn to my Amendment 169A. It is unclear from my reading of the licensing section of the Bill whether the IFR is expected to produce a detailed and granular set of financial rules that would be applied in a blanket way to a large class of clubs or leagues; examples include the specific liquidity ratios, the debt-to-equity ratios, operating cash-flow metrics and size of financial buffers. Or will the IFR take an entirely bespoke approach, where every club will have DLCs—discretionary licence conditions—applied according to their own circumstances? That would drive a coach and horses through the competition organiser’s ability to provide a level playing field and maintain competitive balance. The third option is that the IFR could take an outcomes-based approach whereby it produces some high-level guidance with clear outcomes that clubs must achieve and league rules sitting underneath, giving effect to these principles and outcomes. For example, the IFR could have a series of outcomes relating to working capital, transitionally financed balance sheet health, resilience, protection of assets, et cetera. Leagues could colour in these outcomes into rules.

My own strong preference is for the third option. This amendment, which characterises the third option, is designed to create space for that conversation and, hopefully, allow the Minister to say that, where existing sustainability rules are in place and working, there will be an opportunity for that kind of league-led approach at all levels within an overall regulatory framework. Therefore, my recommendation is an outcome-focused, light-touch regulation, with step-in powers where issues are identified. That is why I have drafted Amendment 169A.

I turn to my Amendments 167A, 168A and 168B. The current test for attaching and varying a discretionary licence condition sets an extremely low bar for the IFR. For example, it seems to me that the test could be met in the case of a club that is already meeting the threshold requirement, on the basis that a discretionary licence condition somehow contributes to the club continuing to meet it.

The DLC test is even vaguer as regards the systemic financial resilience objective. The DLC needs only to advance that objective. While not necessarily the intention, this risks a very unpredictable, wide-ranging and open-ended power that could have a serious impact on club finances. It is also an issue that can be easily mitigated, while still allowing the IFR to meet its objectives. Again, I seek simplicity on behalf of the clubs. I am really concerned that here the detail is so great that it will swamp some clubs.

In the current drafting, potentially the only check on endless interventions, by way of DLCs relating to the systemic financial resilience objective, will be either the IFR’s discretion—in other words, the IFR deciding it has done enough for now—or the IFR being forced to have regard to avoiding adverse effects building up as a result of excessive intervention. Neither of those seems adequate to mitigate the significant risk to English football at all levels. I acknowledge that there is discretion for the IFR to not act in this way. However, I do not think there should be an option to do so, given the very significant risks to English football that would come with the powers being used in this way.

--- Later in debate ---

[Lord Evans of Rainow (Con)]

My Lords, I will speak briefly on Amendment 129 in the name of the noble Lord, Lord Mann. It is relevant to Amendment 93 which, your Lordships may recall, requires the new regulator to regulate football agents. My motivation for that amendment was to try to keep transfer fees within football. As I mentioned, it is very important that the grass-roots clubs that develop the players of the future get their fair share.

The amendment tabled by the noble Lord, Lord Mann, setting out all financial arrangements with external agents and other intermediaries involved in contracts, recruitment or both is an interesting one. My only question is: how will this work in practice? How will the regulator deal with highly confidential multi-million-pound transfers? The noble Lord mentions it being private and confidential and therefore not public, but potential leaks could affect these deals. What would the regulator do? How would he operate? How would he stop or block those transfers? The Premier League still has the best players. We still want to attract the best players. It is vital that we get this right to avoid the trap of unintended consequences. It is so important to protect the international reputation of the Premier League.

My amendment was tabled to ensure that no matter where the transfer comes from, that money stays within football. However, we would have to be careful about how that happened in practice.

[Baroness Grey-Thompson (CB)]

My Lords, regarding Amendments 150, 152 and 164, I will not repeat what has already been said about community assets. I will speak just to my Amendment 248A, which probably counts as a miscellaneous amendment. It is a probing amendment, strong concerns having been raised by the Supporters Trust at Reading. It seeks to insert a new clause, after Clause 51, on ticket pricing, meaning that regulated clubs would have to adhere to the following rules: dynamic pricing strategies being prohibited, concessionary tickets being mandatory and ticket prices for away fans being kept at the level set out in regulations by the Secretary of State. It is a simple amendment, but I suspect that it will not be universally supported.

I understand why clubs want to use dynamic pricing and how it can be used very successfully, but this amendment seeks a more fan-inclusive approach. The Supporters Trust at Reading quoted the Early Day Motion tabled in September 2024, when 19 of the 20 2024-25 Premier League clubs increased their ticket pricing. Abolishing or reducing concessionary tickets would be very bad news for older or younger fans who felt the effects of the cost of living crisis harder than most. Also, Fair Game has said that the constant rise in ticket prices has priced long-standing fans out of the game and that there should be proper consultation with supporters to address their concerns.

I do not seek to open the debate on what a fan is, but this amendment is about giving consideration to how fans can be engaged in discussions about ticket pricing. I am expecting many noble Lords to tell me that this is too interventionist and that it will limit clubs too much, but I am interested to hear the Minister’s response.

[Lord Addington (LD)]

My Lords, going through this long list of amendments, I think that we can all agree that “miscellaneous” is a good description of this group. On what is a competition, I added my name to one of the amendments, but probably should have added my name to the one about heritage. Is it a ground part of the heritage, is it part of the structure, is it what is going on? I should have put my name to this and look forward to the Minister’s reply. If we do not include this, we are missing an important part of why this Bill is justifiable.

Football Governance Bill [HL]

Baroness Grey-Thompson Excerpts

Committee stage
Wednesday 18th December 2024 Lords Chamber

[Baroness Grey-Thompson (CB)]

My Lords, in speaking to Amendments 178, 185 and 199, I draw attention to my interests in the register. I thank my noble and learned friend Lady Butler-Sloss for her contribution to the debate this afternoon.

Among the detail of what a regulator may or may not look like, we spent some time noting para football and how it can change and improve lives, and almost change the world. I would imagine that modern slavery is something that we would want to try to impact. Major games, such as the Olympics and the Paralympics, have made strong commitments in this area, as well as around trafficking. Their success is up for debate, but surely football and sport should try to leave the world a better place, and so I believe that these amendments are important.

Briefly, Amendment 199 is about the ownership of clubs. We have debated Reading and Aston Villa at length. This amendment merely seeks to strengthen the owners’ and directors’ test.

[Lord Pannick (CB)]

My Lords, I think a very strong case has been made this afternoon by the noble Lords, Lord Bassam and Lord Scriven, the noble and learned Baroness, Lady Butler-Sloss, and my noble friend Lady Grey-Thompson to require the regulator to assess whether a prospective owner of a football club respects and promotes the protection of human rights and prevents modern slavery.

I am very sympathetic to the principle. I am just concerned about the practicality. Is it really practical to expect that the regulator is going to have the expertise, time or ability to conduct a general assessment of whether a particular person—who may, for all I know, be based abroad—is generally respecting human rights and preventing modern slavery? This is going to take an enormous amount of time and money, and I fear that it would distract the regulator from the more day-to-day, prosaic functions that Parliament will be asking it to perform. I would be pleased to hear from the noble Lord, Lord Bassam, how this is going to work in practice, because I am very sceptical.