Mr. Ian Drennan:

The best way to answer that question is to say that everything that comes into the ODCE in the nature of a complaint or an expression of concern is treated seriously. It is assessed by reference to its respective gravity, seriousness and so on. The suggestion that anything of a serious nature that comes in would not be dealt with is not borne out by the facts. The possibility that serious issues are being brought to our attention but are not being dealt with as a consequence of a lack of resources is something that just does not happen. If it is sufficiently serious, it is dealt with. We obviously prioritise on an ongoing basis and we reprioritise as necessary. We would never simply ignore something if it is serious in nature.

It might be helpful to set out how we go about dealing with the issues that come across our desks. The first thing that happens is that a preliminary assessment is conducted. For those at the less serious end, we try to deal with them in a cost- and resource-effective manner. We do that through, for example, issuing warnings and requiring evidence of remediation, if necessary supported by a third party, for example, an auditor. If that is sufficiently suggestive or if it evidences that the matter has been addressed, and we get an undertaking that the matter will not be repeated, that will generally speaking be sufficient from our perspective. In the event of a recurrence, we will deal with that accordingly.

At the more serious end, we have a range of options at our disposal. These include civil remedies where an application can be made to the court, for example, an order to compel an individual or a company to comply with its obligations. It is only in the most serious cases that we would conduct criminal investigations.

In essence what I am trying to explain is that criminal investigations are very much the top of the pyramid, for want of a better term. We will only deal with the most serious issues that way. There is an awful lot that happens underneath the water, if you like, that gets dealt with otherwise.