Thursday, 16 November 2023
Employment (Collective Redundancies and Miscellaneous Provisions) and Companies (Amendment) Bill 2023: Second Stage (Resumed)
I made many of the points I wish to raise. I will briefly summarise. My significant interest in this is particularly informed by the experience of the Debenhams workers. The Minister of State is aware they went through an incredible struggle, undertaking 406 days of strike action to try to vindicate their rights. Under a collective redundancy agreement that had been agreed with Debenhams, when the company went into liquidation or they were made redundant, they were to get two weeks' statutory redundancy and two additional weeks' redundancy for each year of service. Of course, they were shafted by Debenhams in the most ruthless manner and did not get anything. The public ended up paying out because the company reneged on its commitment.
The workers set out on their protests and we had multiple debates in the House on the matter. The view of the workers has now been immortalised in a film titled "406 Days". The Minister of State should see it if he has not done so already. It has won multiple awards and will have its UK premiere this Friday. It has been shown in mainstream cinemas. Even the workers and the people who produced it were surprised it was so popular, with large numbers of people going to see it in cinemas throughout the country. It has now gone international and won international awards and so on. Many people identified with the plight of workers, who in this case, although this story has been repeated very often, gave many years of dedicated and loyal service to a company but that company absolutely betrayed the loyalty, trust and hard work those people had put into building up the brand of Debenhams and, prior to that, Roches Stores, which was purchased by Debenhams. They were absolutely gutted. First they were lied to. During Covid they were told it was a Covid-related lay-off, but they then discovered via an email that their jobs were gone and never coming back. That experience has been replicated in this country on multiple occasions but it is something with which people across the world are familiar, and that is why so many people have gone to see the film. Their determination is that should never again happen to a group of workers. They would be looking to this legislation to ensure it does not happen again.
The Duffy Cahill report, which was produced a number of years previous to this, sought to address this kind of situation and ensure that where there were collective redundancy agreements, those agreements would receive preferential creditor status in order that the workers would be at the top of the list when it came to the dispersal of the assets and would receive the redundancy payments that had been committed to them. The Bill does not do that. It does not change the position of the workers. It provides a 30-day window and gives them greater access to information relating to the financial position of the company and the process of liquidation. It gives workers the right to go to the Workplace Relations Commission, WRC, if the 30-day window is breached, but a company that breaches the window will be fined only €5,000. I do not see how that will inhibit a company. In the case of Debenhams, given the amount of money that was at stake, it would not have been worried about a fine of €5,000 for breaching the terms of what it is supposed to do here. If that is the penalty a company will suffer, I do not see how it will be a disincentive in any serious way.
I will remind the Minister of State what the workers and I think happened. It was a tactical liquidation. Unbeknown to the workers, Debenhams UK had taken out a €200 million loan facility from a consortium called GLAS Trust which involved US hedge funds, Bank of Ireland and Barclays Bank. It had imposed the €200 million debt on the Irish company two years before, as far as I remember. The Minister of State can check the details on this. The workers did not know about the imposition of that debt, however. They were initially told the financial position of the company was that it was €19 million in debt. They took some comfort from that because the Debenhams online business was still functioning and generating significant amounts of revenue and they knew there were assets in the company stores throughout the country that likely far exceeded the €19 million debt. They had good reason to believe there were sufficient assets available, in terms of the continuing revenue to the online businesses and the physical assets in the possession of the company, for them to get their two weeks' statutory and two weeks' additional redundancy from the assets of the company. They then discovered, however, that the financial position of the company, rather than being €19 million in debt as they were told by the liquidators, was actually €225 million in debt. The way in which that was triggered could not have been done until precisely the moment it was done. This debt facility was established one or two years previously but it could not crystallise on the company until precisely the moment it did. In other words, it was preplanned. That meant GLAS Trust, which had lent that money to Debenhams UK, became the owner of the company and got all the assets. It got all the assets and the workers were left with absolutely nothing.
The question is whether this legislation deals with that. Having talked to the Minister of State's officials, they said there are additional remedies, that the scope of it is quite wide, and that the pool of assets will be broadened. In view of this sort of premeditated tactical liquidation, as it would seem to the workers happened in this case, I would like reassurance that the Bill would guarantee, and I do not think it really is the case, that workers would get the first call on those assets rather than what were essentially vulture funds. They were vulture funds that, in what looks like a deal with Debenhams UK, loaned the money knowing quite well that after they sold off the Danish company, which was released of that burden of debt, it was all loaded on the Irish company. This was a company that was actually in a reasonably decent financial position, particularly when it took on the online business. Instead, all the debt was loaded on it. The question is whether we can prevent that from happening again, where workers do not get shafted and are at the top of the list ahead of vulture funds, which are essentially engaged in financial manipulation of the company to be able to asset-strip it? That is what actually happened.
It seems to me this does not guarantee that is the case, even if, as I understand it, and I am not the expert and the Minister of State's officials are probably far more expert on this, a person could go to court under the Companies Act 2014. Again, for workers who have nothing, have lost everything and would not have much resources, how the hell are they going to fight their way through the courts trying to work out whether there is any legal remedy for them? That would be a hugely costly process. That is not much comfort really because these companies with their lawyers and these vulture funds with all the assets and resources they have mean the chips are very heavily stacked against the workers in those circumstances.
Maybe the Minister of State has answers to all these questions. Certainly, it seems to me we need to absolutely guarantee that this sort of manipulation and asset stripping to prevent workers getting their fair redundancy, as happened in Debenhams and other situations, can simply never happen again and that the workers who contributed to all the profits those companies made over decades and to the value of the brand and so on are the ones who get first call on the assets in the company before anybody else does so they are not shafted. I am sorry to use slightly colourful language but it is very difficult to find another way to describe it. The Debenhams workers were absolutely shafted. Frankly, it would be a fitting tribute to the heroism of the Debenhams workers, who were treated so badly, that we absolutely guarantee that such a thing could never happen again.
I welcome the Bill, which has been a long time in preparation. As somebody from Waterford who has witnessed the effect of the liquidations of TalkTalk, Debenhams and, most recently, Iceland, I can honestly say the loss of employment is a significant hurt. The denial of agreed redundancy payments becomes a toxic burden for workers to handle because, in my opinion, it shows their employers see little of future value or commercial value in them. It is this sense of injustice that forced workers in all of these companies to vehemently protest the treatment they were receiving. In the case of Debenhams, this resulted in a strike exceeding 400 days' duration, where workers did their utmost to prevent the movement of stock in the hope that its sale could realise some of their promised benefits.
It is a fact that companies do and can engage in strategic and tactical liquidation. In the case of Debenhams, and Clerys before it, one could question how UK companies could put assets beyond the reach of workers yet, at the same time, still get full access to their Irish market profits without any legal encumbrance pre-liquidation. It is also a fact that the legal procedures around tactical bankruptcies and asset stripping are often largely completed before workers' rights can be vindicated or enforced.
As a member of the Joint Committee on Enterprise, Trade and Employment, our grouping did a significant examination of the proposals of this Bill and we made several recommendations. I welcome the formation of the plan of action, which has been welcomed by the social partners and informed by the work of the Company Law Review Group, a group made up of a wide range of stakeholders, including business associations, trade unions, legal practitioners and, most importantly, insolvency experts. Importantly, I welcome the Department's engagement with Restructuring and Insolvency Ireland, which represents insolvency practitioners across the country. This is the type of stakeholder involvement needed to deliver better legislation.
There are significant and obvious additional benefits to employee rights within this Bill, not least the requirement that collective redundancies would now be subject to a 30-day notification. Employees may also seek redress of up to four weeks in remuneration from the Workplace Relations Commission if the employer makes them redundant before the 30-day notification period finishes.
An improvement to the Bill that I wholeheartedly welcome would be the requirement that where a liquidator is managing the collective redundancy process in an insolvency situation, they must fulfil the employer's obligations. This goes to the heart of workforce issues in the Debenhams workers' strike, for instance, in Waterford and around the country. Many of the workers who fought for recognition of their rights will, I believe, welcome this proposed statutory change.
The Bill also proposes the establishment, on a statutory footing, of the employment law review group, an oversight group to make an assessment of employment and redundancy law and to ensure employment law remains adequately robust and fit for purpose into the future. A range of professionals are proposed to join this body, including, again, insolvency experts and employer representatives. It would be important that there is adequate balance between the interests of employers and employees in the nominations to this body.
I welcome the intention to change the aspects of the Companies Act that guides the framework in which companies and directors operate and that seeks to ensure better regulation around which commercial companies also operate. The main intention appears to be providing greater accountability in the event that assets are put beyond reach, and the proposal can provide for retrospective legal action to require a company to contribute to the debts of a subsidiary company being wound up. This appears to me again to be an initiative that has been generated by the courageous and principled stand of Debenhams workers, in particular, who could have singularly benefited from this legislation if it had already been in place.
Overall, this proposed Bill attempts to offer significant increased security for workers who are made suddenly redundant in understanding they have rights to be pursued. However, as laudable as this is as a moral employment ethic, it must also be balanced against a requirement of our economy to inspire and deliver entrepreneurship. What I mean by this is that it is often the case that companies facing cash flow squeezes may not be in a position to immediately resource their company pension funds or their statutory employment obligations. While this Bill seeks to protect workers' rights, it must also be cognisant of the need to understand the commercial landscape businesses operate in. Where companies are facing cash flow difficulties or significant revenue loss as a result of, for example, debtor failures, stock writedown, business interruptions, etc., I would like to see some direct avenue to the Department for companies seeking temporary State support, especially where pillar banks have shown no appetite to provide such support. A request such as this is far more pertinent to our domestic indigenous business sector, which is facing a difficult business horizon now and into the future.
Having access to work is as important as having proper remuneration and redundancy rights within it. Creating a new business venture and even keeping a successful business venture operating profitably is also important, but it is difficult and if often presents significant commercial risk to founders and investors. As well as having robust employment law, the Department must now engage itself in reviewing both entrepreneur supports and business support access for companies that require additional financial help from time to time, which in all likelihood is rarely available from commercial lenders. Often, where it is available, it is inadequate to the task at hand and prohibitively expensive.
We want to have a thriving economy that is the basis on which we can build an equitable, just and fair society. While I welcome that workers' rights, particularly in respect of access to redundancy, are being strengthened by this proposed legislation, as I said, we need a secondary dual focus in Government and across the Department.
We must protect our indigenous manufacturing service economy. Ultimately, if those businesses cannot survive and thrive into the future, there will be no employment on offer and, therefore, future redundancy rights of workers will be a moot issue.
I welcome the increased protections proposed for workers and their families in the event of company insolvency and liquidation. If the Bill, when finally agreed, removes the future spectre of low-paid workers camping out for months in wind and rain in an effort to vindicate their employment and redundancy rights, it will be a very good thing. Such an outcome, even of itself, would merit the passage of the legislation.
I am sharing time with Deputy Pringle. I do not know whether I welcome the Bill. It is an indictment of our political system that it has taken more than eight years to address the injustices the Clerys workers faced in 2015. Since then, we have seen the Debenhams workers left out to dry due to a failure of this House to act on collective redundancies. More recently, we have seen the disgraceful treatment of the Iceland workers by their boss, Naeem Maniar. These are just a few examples of the failures by successive Governments to legislative to protect workers. We all knew there was a problem. Workers who lost their livelihood received little to no compensation because of this issue. Still, no action was taken. This Bill should have come a lot sooner.
I support the measures in the Bill to implement the Duffy Cahill report, apart from these provisions being far too late for the Clerys, Debenhams or Iceland workers. Without context, this is not a bad Bill, which is why I am not sure whether I welcome it. It is better than what we had before. However, it is, in effect, attempting to fiddle around the edges of an issue that has a clear and simple solution. On 4 October, I asked during Questions on Policy or Legislation if the Government would make it a priority to progress the Companies (Protection of Employees' Rights in Liquidations) Bill 2021, known as the Debenhams Bill, or introduce its own legislation to ensure workers are paid wages, sick pay, holiday pay and agreed redundancy payments where the employer files for bankruptcy or uses tactical insolvency. The Minister, Deputy Coveney, replied that he planned to introduce new legislation on collective redundancies in the next few weeks. He said it would not deal with all the issues I raised but certainly would deal with some of them. In fact, the Bill has not covered a lot of the issues that should be covered.
There is a simple solution to this issue. Workers can only be fully protected in collective redundancies if they are given preferential creditor status. Our Bill, the Companies (Protection of Employees' Rights in Liquidations) Bill, known as the Debenhams Bill, would bring Ireland in line with many other countries, such as Greece, France and Portugal. I do not know why the Government seems to think Irish workers are less important than Greek, French or Portuguese workers. It has done everything it can to tie up our Bill in the Dáil, as it does with may other Bills, despite the support it received from many in this House and in the trade union movement. During pre-legislative scrutiny, our proposals received extensive support from Mandate and the Irish Congress of Trade Unions, ICTU. Instead of supporting those proposals, the Government has introduced a Bill that ignores the most important solution to the problem and does not even include all the recommendations of the Joint Committee on Enterprise, Trade and Employment. The recent situation with the Iceland workers is a clear example of how weak our labour laws are in this country. After months of repeated reports of systematic non-payment of wages, sick pay and holiday pay, we saw the company loaded with debt and run into the ground by Naeem Maniar. The Government stood by and let this wage theft happen, despite multiple appeals by the union representing the workers, the Independent Workers Union, for intervention to protect them. There was no support for Iceland workers. They walked away with nothing but statutory redundancy while the owners of the company got to walk away with their debts cleared.
This law is weak and, unfortunately, has no teeth. A real look is needed at the legal loopholes and tricks companies and their owners can pull to hide assets and cheat workers and other creditors. I am glad there is a tightening in the Bill of company law with regard to liability. However, we will see more workers cheated and left out to dry until we put a system in place where there is zero tolerance for moving debts or assets, preferential status for workers and enforcement with real teeth to hold people to account for contravention. I will support the Bill and I am sure I will support many of the amendments that need to be made to it. I reiterate that it does not tackle the real issue. It does not give workers preferential creditor status. Our system will continue to allow workers to be let down, cheated and left out to dry until we legislate to put them first in collective redundancies.
I welcome the opportunity to contribute to the debate on the Bill. I confess that I am not fully up to speed on it as I am not a member of the relevant committee and have not participated in the debate there. My knowledge may not be as full as it should be. It is my understanding that much of what is contained in the Bill arises from the high-profile redundancies in Clerys, Debenhams and the like. Workers had to fight for some recognition that they were an integral part of the companies being wound up and that those companies should have an extra responsibility for their workers above what is prescribed in law at the moment.
My study of the legislation, limited as it has been, suggests that what is required has not been done fully. Most of its content seems to be about looking like provision is being made without actually doing it. The easy parts, such as provision for notifications, are done, but the real rights workers deserve are not being given. Companies have personality status and they seem to be the be-all and end-all as far as legislation that comes through this Parliament is concerned. Sadly, workers are left behind and, unfortunately, that seems to continue in this Bill.
The Bill requires at least 30 days' notice of any collective redundancies and gives employees better advance notice of the winding up of a company. It also places the onus on the receiver to continue the 30-day notice period. That will help workers to protect their rights and have the ability to get organised and fight. There is a lot of emphasis in the legislation on penalties for failure to provide notice. I wonder whether any company directors or insolvency practitioners have ever been fined in cases where they have not carried out their duties. I would be interested to hear about any such situations. We hear a lot of talk about sanctions, which are often included in legislation, but I wonder whether they are ever used. If a sanction has not been used and will not be used, it is of no use.
The proposals for the amendment of the Companies Act 2014 seem interesting and have value. The provision for dealing with employees as creditors is welcome, and requiring them to be given information is vitally important. However, I am not yet sure what these provisions will mean in practice for workers. How they work will be the crux of the legislation. Unfortunately, we must wait a couple of years to see whether the Bill works. If we decide it does not work, it will be another ten or 15 years before legislation is introduced to correct the issues. That is the problem. We should be protecting workers and getting beyond these issues.
Giving the courts the power to order a related company to contribute to the debts of a company being wound up is welcome. I wonder how that would have impacted on the Debenhams situation, for example, where the UK parent was continuing to trade through a website that was available in Ireland and making a lot of money in so doing. I am not sure whether this legislation could be used to tackle a parent company in those circumstances. We will need to see what happens in practice.
My reading of the Bill digest suggests the Bill will have a limited effect in helping employees. The Department seems to have modelled it on the New Zealand approach, which does not meet the needs of employees. That is the reality. The Department's excuse for not including powers is that it does not want to create preferential treatment for redundant workers over workers in other situations. Surely being made redundant makes a worker preferential and in a different situation from other workers? This should be looked at and addressed in legislation. Being made redundant due to a company folding is different from workers being made redundant as a consequence of a company restructuring or where the company is otherwise continuing on but changing what it is doing. That is the whole basis of these disputes and it needs to be addressed. The State has made provision for statutory redundancy requirements and so on and workers are protected as creditors in that situation. Next in line could be the workers who should have an entitlement above statutory redundancy. They could be protected in that way. At least the State would be seen to be saying that these workers should be protected as a priority. Unfortunately, we do not seem to be going down that road.
We just seem to be putting on a show of them being protected when they are not really. It is a semblance of doing something without actually doing it. I could be wrong on that, though, and if I am, I would be happy to say so at a later stage. Unfortunately, time is the only thing that will tell on this matter.
I am delighted to have the opportunity to conclude the debate on this Stage. I appreciate the comments made by the Deputies this evening. I listened closely to the debate with the Minister, Deputy Coveney, yesterday. I will start by trying to respond to some of the comments and questions that were raised by Government and Opposition Deputies.
I welcome Deputy O’Reilly’s strong support for the Bill and I look forward to engaging further with her and other members of the committee on Committee Stage. I also welcome Deputy Nash’s strong support for the Bill, particularly the former Minister of State with responsibility for business and employment who initiated a review of employment and company law in the wake of the Clerys situation. In response to his comment on the level of redress provided under the Protection of Employment Act, as amended by the Bill, and as the Minister stated, this new form of redress is in addition to the existing rights under that Act, the Minimum Notice and Terms of Employment Act and the Unfair Dismissals Act.
Our focus is on creating a culture of compliance. We do not simply want to provide redress; we do not want redress to be required in the first place. What we want is for employers and others to comply with their obligations. The Workplace Relations Commission and Corporate Enforcement Authority both have a role to play in respect of different aspects of this culture of compliance and I am committed to ensuring that they can play their independent roles.
Reflecting the recommendation of the joint committee’s pre-legislative scrutiny report, my Department will update the collective redundancies information handbook, which was published in 2021, to reflect the changes in the Bill. This is a living document and will be updated as required.
I welcome the clear cross-party support from Deputies O’Reilly, Martin Kenny, Nash, Catherine Murphy, Marc Ó Cathasaigh, Cathal Crowe, Joan Collins and Pringle - to an extent, based on the tenor of the debate - for the statutory establishment of the employment law review group, ELRG. I agree that the group will add significant value to the review of employment law in the State. Its establishment will ensure our suite of employment and redundancy law remains robust and fit for purpose in the rapidly changing world of work. It is important to emphasise that the ELRG will be an expert and technical advisory group rather than a consultative group for social dialogue like the Labour Employer Economic Forum. Accordingly, its membership will be drawn from those with expertise in employment law, accountancy and insolvency professionals, academics, regulators and representatives of employers and workers. There will be an open call for expressions of interest and I will seek nominations from relevant bodies, including the WRC, the Labour Court, Departments and representative groups. The group's terms of reference will accommodate a non-statutory declaration of conflicts of interest.
A number of Deputies discussed the Duffy Cahill report in the context of Debenhams. The Duffy Cahill report was in response to narrow and specific terms of reference and where assets of significant value were separated from the operating entity before liquidation. The Government’s stated policy in this space – the Plan of Action on Collective Redundancies following Insolvency – considered and responded to each of the Duffy Cahill recommendations. Debenhams is the subject of an ongoing High Court-supervised liquidation, so I am reluctant to be drawn into too much of a discussion about it. As has been mentioned in the House, though, if anyone has information that suggests wrongdoing under company law, it should be brought to the Corporate Enforcement Authority's attention.
I fully acknowledge the impact on the Debenhams workers who were made redundant early in the pandemic. The Government always sought to ensure that their concerns were heard and the State’s welfare, employment and training services responded to their needs. The Government extends that same responsiveness to all employees facing the difficult prospect of redundancy. The Social Insurance Fund provides a safety net for employees to ensure they receive statutory redundancy and other wage-related entitlements in situations where the employer cannot pay due to insolvency. These rights have been honoured by the State in the case of the Debenhams workers at a cost of over €13 million. In recognition of the exceptional circumstances of this case, and as reflected in the report by the chair of the Labour Court, the Government also provided an additional €3 million fund to support career guidance, training, education and pre-retirement planning for the former Debenhams workers.
Deputies O’Reilly, Martin Browne, Ó Murchú and Boyd Barrett raised the matter of enhanced redundancy payments. All eligible employees are entitled to a statutory redundancy payment and, where an employer is unable to pay, the State steps in to ensure this is honoured. In an insolvency situation, employees are already considered preferred creditors in terms of wage arrears, outstanding holiday pay, pension scheme contributions and statutory redundancy. Their statutory entitlements are also guaranteed by the State via the insolvency payments scheme.
Enhanced redundancies over and above this statutory entitlement are a voluntary matter between employers and employees. Ireland’s system of industrial relations is based on a voluntary approach and collective agreements are not binding in law. Providing for enhanced employee entitlements would have serious consequences. It would risk creating two classes of employees, with a special class of worker who is made redundant due to insolvency granted enhanced legal rights that go beyond those afforded to workers who are made redundant for other reasons. This could be constitutionally unsound. It would have a knock-on effect on other creditors, such as SMEs and suppliers, who are themselves employers and who, due to liquidity issues, may find themselves making their workers redundant. As preferential debts include rates and taxation claims, the State is also a preferential creditor and such a proposal would adversely affect the Exchequer, depriving the taxpayer of moneys owed to local authorities, the Department of Social Protection and Revenue. It may also incentivise employers and employees to agree enhanced collective agreements ahead of insolvency situations in the knowledge that they will be funded from the sale of assets and-or State funding via the Social Insurance Fund.
Deputy Catherine Murphy queried the balance of rights that underpins the Bill. It is worth remembering that, while certain insolvencies have attracted negative headlines, most company directors want to do the right thing and do their best to act accordingly. Companies are entitled to arrange their affairs in a manner appropriate to their needs, provided those arrangements comply with the law. However, where there is non-compliance with the law, remedies and individual accountability are important. The Bill amends the remedies already available to creditors in those cases where assets are removed from the reach of creditors, but these changes are being introduced in a way that guards against unintended consequences.
Deputy Boyd Barrett raised the issue of costs. The question of costs is always something that a person going to court will have to weigh up. A review group considered the issue of improving access to civil justice and reported to the Minister for Justice on its recommendations for change, including reducing the cost of litigation. The Department of Justice considered the recommendations and published the implementation plan on civil justice efficiencies and reform measures in May 2022, which set out the approach to reforming the administration of civil justice in Ireland. Under this plan, the Department of Justice has considered that third-party funding should be available to liquidators to fund proceedings intended to increase the pool of assets available to creditors. This recommendation will be implemented by the Department of Justice through primary legislation, with a target date of being enacted in 2024. We will, of course, actively engage with our colleagues in that Department as necessary.
This is a significant and complex piece of work. It changes the employment, redundancy and company laws on the matter in a meaningful way. As has been remarked by a number of Deputies, this Bill was brought about after long-considered preparation by officials and stakeholders alike as well as a detailed pre-legislative scrutiny process. It is an important further step in implementing the outstanding legislative commitments in the plan of action, which represents the Government’s considered policy response to the complexities arising in such situations.
It is important to remember that workers already have robust legislative protections and safeguards as employees under employment law and as creditors under the Companies Act. This Bill will further benefit the workers of insolvent employers in a number of ways. It will improve awareness and increase transparency for employees of insolvent employers, improve access to the mechanisms that can increase the pool of assets available for the creditors, and provide for the statutory establishment of the ELRG, which will ensure employment and redundancy law is fit for purpose.
The Bill has been prepared in consultation with various stakeholders. In particular, I thank the Company Law Review Group for its considered work on the matter of company law and the Office of the Attorney General for its efficient preparation of the Bill. The Government’s response to the various crises has proven successful in mitigating the immediate impacts on companies. However, with the exceptional decrease in insolvencies in recent years, we now anticipate a reversion to pre-pandemic levels of corporate restructuring and insolvency in the coming months and years. Therefore, it is incumbent on us to strengthen further the already robust legislative protections and safeguards afforded to the employees involved.
I know that my colleagues recognise the importance of having an appropriate and considered legislative framework in place that deals with the generality of collective redundancies following corporate insolvency. I hope there can be cross-party support to ensure that we get this Bill enacted as soon as possible. I assure the Deputies that we have carefully considered the recommendations in the pre-legislative scrutiny report. In our analysis, some of those recommendations are not necessary. This is not because they are without merit, but because they are already addressed in law. I very much look forward to a further detailed engagement with Deputies on these issues on Committee Stage.