UK: Building Society Update - Twin Challenges - Issue 7, Spring 2011

Last Updated: 23 June 2011
Article by Deloitte Financial Services Group

Most Read Contributor in UK, August 2017


Stephen Williams

We are entering better times. Strong capital levels and robust governance structures are now in place at most building societies.

However, economic uncertainties remain, downside risks are prevalent, and new capital requirements and forthcoming regulation could damage the sector.

In this publication we have provided our thoughts on a number of key areas of interest and concern for the industry such as raising governance standards, the UK Bribery Act, the potential implications of the International Accounting Standards Board's proposals and the FSA's new Remuneration Code.

In addition, we have also performed a survey. This has reviewed the capital position of a significant sample of the largest 40 building societies. From our review, we have concluded that all the societies sampled would meet the core tier 1 requirements set out in Basel III in December 2009, including the additional 'conservation buffer' of 2.5%. Of the societies sampled, 80% would also have core tier 1 ratios in excess of 10.5%.

It is therefore clear that despite the challenges that new regulation like Basel III can present, societies appear to be well placed to respond to requirements for increased levels and quality of capital, funding and liquidity. This is down to societies typically having a generally low reliance on short-term wholesale funding, prudent levels of liquidity holdings, limited appetite for innovative capital instruments and dependence on retained earnings.

I hope you enjoy the read.

Governance in building societies

In this short piece we take a look at the current state of building society governance. Always an important issue, improving governance matters now more than ever. We examine the numerous market challenges facing our sector, from Treasury, rating agencies, investors and the effects of the Walker report, and make recommendations as to how societies should react, as well as approaches to consider, concerning risk and remuneration.

Why is governance important?

For individual societies:

  • A strong Board will drive the society forward in these continuing uncertain times. However, to remain competitive, the governance framework must also be both effective and flexible to enable decisions to be made quickly.
  • Effective governance provides the society with the ability to move the risk appetite quickly and in a controlled way.
  • An effective governance framework maintains confidence from all stakeholders – including possible capital providers and longer term funding counterparties.
  • Effective governance ensures the regulators see the society in a positive way.
  • NEDs have a particular "Trust" like responsibility to manage the society in the interest of present and future members.

For the sector as a whole, improved governance is required in order to provide comfort to the FSA. This may enable them to relax the boundaries of the Building Society Sourcebook, providing individual societies with greater strategic flexibility.

Where is governance at this time within the building society sector?

There are some fantastic examples of strong governance throughout the sector, but there are also some immediate pressures:

  • Reputational issues for the sector continue, and there is a perception that the FSA now sees the sector as part of the problem, and blames poor governance within the sector allowing this to occur.
  • Building Society Sourcebook – need for alignment of governance and risk management systems and skills with business models and activities.
  • Credit rating agencies – the credit downgrades have caused difficulties especially for those societies who are dependent upon covered bond programmes and other forms of wholesale funding. The agencies are demanding better governance.
  • Institutional investors – PIBs and subordinated debt holders are demanding better governance, given the losses they have suffered in a number of transactions recently.
  • The building society sector will need to continue to look for alternative ways of raising permanent capital and longer term liquidity. However, any new "equity" investor will demand better governance (and also require the interest of such investors to be met).
  • The Walker Report.

How should societies react?

At the Board level what is important?

  • Balanced board composition – boards will require a blend of experience – financial industry expertise, business experience and independence. However, it is important that certain Board members also have an allegiance to the locality and to the hinterland of the society. This is an important balance and is often hard to achieve.
  • Time commitment needs to be increased for Board members – Walker stated a minimum time commitment of 30 to 36 days for NEDs on a major bank – but what about a building society? Walker also stated that a Chairman should devote two-thirds of their time to the business of the entity for a major bank – again, what about a building society? At the very least the time commitment required has increased, which will limit the capacity of NEDs to retain or assume board responsibilities elsewhere.
  • In these times, personalised induction, training and development plans need to be in place for NEDs.
  • New approach to meetings – rigorous challenge should be the norm, and NEDs should be ready, able and encouraged to challenge and test proposals on strategy put forward by the executive. In particular, NEDs should satisfy themselves that board discussion and decision-taking on risk matters is based on accurate and appropriately comprehensive information and draws, as far as they believe it to be relevant or necessary, on external analysis and input.
  • There will need to be externally-facilitated board performance evaluation.

Risk Committees

Board Risk Committees should also be established where these are not in place. However, for smaller societies perhaps these can be established as part of a dedicated separate agenda within the framework of the Audit Committee with common membership. Increasingly, annual reports will also be required to describe risk strategy, appetite, and tolerance.

There is also a journey that should be embarked upon in the appointment of a Risk Officer. There are few examples at this time of the appointment of Chief Risk Officers, but there is a need to start this journey. This will elevate Risk within the society and create a greater level of independent challenge. The Risk Officers tenure, remuneration and removal should also require Board approval.


The Walker Report stated that at least half of executives' compensation should be performancerelated long-term reward. This is an entirely separate debate but it is important that pay is linked to long term member value through whatever arrangements are established.

There is definitely also a need for an increase in the oversight of remuneration policy and packages for all executives who perform a significant influence function for the society, or those who could have a material impact upon the risk profile of the society.

Other matters

This list should not be exhaustive but Board's should also consider:

  • The positioning of the Risk and Compliance department.
  • The roles of the Boards of individual regulated entities within the Group.
  • The adequacy of the conflicts of interest policy in place.
  • The effectiveness of the whistleblowing procedures in place.


Many building societies are reacting positively to the increasingly competitive market, and would appear to be well positioned in the present market uncertainty.

In particular, the sector continues to retain a strong local presence through extensive branch networks, with continuing strong links between building society brands and their local communities.

However, improved governance will ensure that the building society model continues to provide sustained and long term value for current and future members.

UK Bribery Act Raising the bar

On 30 March 2011 the Ministry of Justice published the finalised Adequate Procedures guidance on the UK Bribery Act 2010; becoming effective on 1 July 2011. The Act introduces stringent legislation to prevent bribery and more readily enforceable offences that organisations, including UK building societies, will need to factor into their risk management processes going forward.

Penalties and offences

The maximum penalty for bribery under the Bribery Act is increased from seven to ten years imprisonment with an unlimited fine. Perhaps more significantly, the Act is silent as to how fines on companies will be calculated – it may open the door for larger scale fines, in line with those levied in the US. High profile examples of these include the fine paid by Siemens amounting to $1.6bn and by Halliburton amounting to $579m.


The Bribery Act contains:

  • Two general offences of making or offering to make a bribe and receiving or soliciting a bribe.
  • A new specific offence covering bribery of a foreign public official to influence them in the performance of their duties.
  • The Act also creates a new offence under section 7 of the Act for failure of a commercial organisation that fails to prevent persons associated with it from committing bribery on its behalf.

Associated persons could include not only employees, agents or subsidiaries but a wide population of third parties who perform services, for or on behalf of an organisation. This potentially creates a significant risk of liability for a society under the Act.


  • Section 7 of the Act applies to organisations operating in the UK (even if not UK registered), and to UK based organisations conducting business anywhere in the world, including the conduct of associated persons as mentioned.
  • The Act is far reaching in terms of the offences and activities that it covers e.g. excessive or overly lavish corporate hospitality.

Appropriate defence

The Act provides for an organisation to defend against the section 7 offence of failure to prevent bribery, if it has adequate procedures in place to prevent associated persons from committing bribery, for or on its behalf.

The following six principles, set out in the finalised guidance, may help you decide whether you need to be better prepared:

Proportionate procedures – a society should have anti-bribery and corruption procedures that are proportionate to the specific risks faced by the business – and appropriate to the nature, scale and complexity of its activities.

Top level commitment – senior management should be able to demonstrate their commitment to preventing bribery, establishing a culture that supports this commitment and communicating the society's anti-bribery policy throughout the organisation.

Risk assessment – the society should perform a regular and comprehensive assessment of the nature and extent of its corruption risks.

Due diligence – the society should understand the background and reputation of the parties with whom it does business.

Communication (including training) – societies' anti-bribery policies should be effectively embedded in day to day business processes.

Monitoring and review – the society should implement appropriate monitoring and review mechanisms to ensure compliance with relevant policies and procedures.

Practical implications

Do you need to carry out due diligence of all your suppliers?

You only need to think about doing some due diligence on persons who will actually perform services for you or on your behalf. It is very unlikely that you will need to consider carrying out due diligence on someone who simply supplies goods to you or persons further down the supply chain.

Is hospitality, promotional and business expenditure permitted?

The Act does not intend to prohibit, hospitality, business expenditure and promotions for the purpose of improving the image of the organisation, or to build or develop relationships, where it is reasonable and proportionate. For example, the guidance states that in order to amount to a bribe under section 6 of the Act, (bribery of a foreign public official), there must be an intention for a financial or other advantage to influence a person in his or her official role, and thereby secure business or a business advantage.

In our experience when corrupt payments have been made by employees, representatives or business partners of an organisation, some key questions asked by enforcement authorities include:

  • Did the organisation effectively communicate the policy regarding bribes, and that they should not be offered or paid on its behalf to the employee, representative or business partner? And;
  • Did the organisation effectively control and monitor the activities of the employee, representative or business partner to ensure compliance with the policy?

We would suggest that these questions are useful considerations when senior management are assessing the adequacy of anti-corruption procedures and controls.

Questions senior management should be asking now

In light of our experience working on enforcement actions, and designing and developing anti-bribery and corruption, and our knowledge of the existing guidance, we have set out questions we believe senior management should be asking regarding their anticorruption policies, procedures and controls. To the extent that the answer to any of the questions is "No", we would suggest that senior management need to review the relevant policies, procedures and controls and take appropriate remedial action.

  • Does the society regularly perform a corruption risk analysis on its operations in order to identify potential high risk areas and ensure the continued effectiveness of the society's anti-corruption procedures? Factors to be considered would include:
    • business conducted in countries with a high propensity for corruption, which is probably only relevant to a few societies if indeed any;
    • business conducted through financial advisers, joint ventures or other third parties; – business conducted with government customers;
    • business conducted with organisations in industry sectors with a high propensity for corruption;
    • operations where business entertaining is a significant element of the sales process; and
    • previous incidents of bribery within the society or the industries/countries in which the society operates.
  • Does responsibility for anti-corruption procedures rest with a designated member of senior management with appropriate access to the board?
  • Does the society have a clear anti-corruption policy and code of ethics that are visibly and consistently supported by senior management creating the appropriate "tone from the top"?
  • Does the society provide regular training on its anticorruption procedures to its employees, representatives and business partners, and are the recipients of this training documented?
  • Are employees, representatives and business partners required to certify on a regular basis that they have read and understood the society's anti-corruption policy and complied with its provisions?
  • Are anti-corruption procedures and controls included in day to day business processes? Examples would include:
    • due diligence on prospective financial advisers, joint venture and other business partners. This might include making enquiries with local chambers of commerce, business associations, requesting financial statements, CVs and other references;
    • appropriate review and authorisation controls over the nature and purpose of payments;
    • right of audit over the activities of any financial advisers, joint ventures and business partners; and
    • specific procedures and controls covering the areas of gifts, hospitality, entertainment, customer travel, political contributions, lobbying activities, charitable donations, sponsorships and facilitation payments.
  • Does the society have a system of internal controls designed to maintain accurate books and records and prevent their use to facilitate or hide corrupt payments?
  • Is compliance with the anti-corruption procedures performed by employees, representatives and business partners regularly monitored by the society, for example through Internal Audit visits and/or data interrogation techniques?
  • Does the society have a mechanism in place for providing specific and immediate guidance to directors, officers, employees, representatives and business partners on complying with the society's anti-corruption procedures when dealing with potentially problematic situations? One example would be a compliance help line.
  • Does the society have a mechanism in place to allow employees, representatives and business partners to report suspicions of corrupt activity in a confidential manner, for example through a telephone hotline?
  • Does the society have a response plan in place to deal quickly and effectively with incidents of potential corruption?
  • Does the society have appropriate disciplinary procedures that address violations of relevant anticorruption laws and the society's anti-corruption procedures applicable to employees, representatives and business partners?
  • Does the society promote its anti-corruption procedures to its employees, representatives and business partners through its performance management processes?
  • Does the society factor corruption risk into its transactional due diligence programs? Corruption issues can be a key issue in the "buy" decision and are better dealt with pre rather than post acquisition.

Summary – Key messages

  • The UK Bribery Act has become law introducing strict liability for corporate offences relating to the failure to prevent bribery occurring within an organisation. The only defence is that adequate procedures have been established to prevent bribery.
  • A well controlled business is likely to have a substantial amount of the requisite control processes in place to be able to demonstrate adequate procedures – but they need to undertake an exercise now, and on an ongoing basis, to assess to confirm that this is the case.

The Act and more information can be found on the Ministry of Justice website.

The changing world of IFRS

The IASB is currently revisiting some of the principal elements of IAS 39 in response to feedback received on the impact of the standard, in the context of present economic conditions. The revisions are being reflected in IFRS 9.

The new standard will result in several significant changes to the accounting for financial instruments. Whilst the amendments to hedge accounting rules are likely to be helpful, the move to an expected loss impairment model in particular could bring several challenges, including a negative impact on capital and a possible dampening of future profitability.

So who is impacted?

The changes will impact both those currently reporting under IFRS and those undertaking the transition from UK GAAP to IFRS between now and 2014.

Impairment methodologies – a return to "good old UK GAAP"?

Not quite but for those societies that reluctantly released general provisions on adoption of IFRS, there may be some feeling of frustration.

The Exposure Draft (ED) issued in December 2009 proposed an 'expected loss' model, which would result in a smoother recognition of losses over the life of the loan compared to the incurred loss model. At present, interest is front-loaded (which includes a premium to cover the lender's expected losses) with 'lumpy' impairment losses recognised later during the instrument's life.

The IASB received a significant amount of feedback on the ED, much of which was positive; however a number of practical difficulties were identified in implementing a full 'expected loss' model. As a result, a supplement to the Exposure Draft was released in January 2011, in which the following model is proposed:

  • Recognition of lifetime expected credit losses using a time-proportionate approach for financial assets in a 'good book' and full recognition of lifetime expected losses for financial assets transferred to a 'bad book'.
  • There will be a minimum 'floor' level of provision against the 'good book', which is likely to be the losses expected in the upcoming year.
  • The time period for estimated losses relating to the 'bad book' would be the reasonably foreseeable future, being a period of at least 12 months.
  • The definitions of 'good book' and 'bad book' will require the exercise of some judgement. The latest guidance suggests that loans enter the 'bad book' at the point where the business' approach to collections changes.

In addition to changes in the accounting requirements, IFRS 9 will include enhanced disclosure requirements, which are expected to include the following:

  • Analysis of 'good book' and 'bad book' and where applicable a reconciliation to nominal amounts in the 'bad book', including disclosure of the gross provision amounts, and details of write offs from the 'good book'.
  • Disclosure in a tabular format of factors impacting credit losses for the 'good book' with five years of information. This would include lifetime expected losses, balance of outstanding nominal amounts, and any additional provision required to reach the 'floor'.
  • A comparison of expected losses with actual outcomes.

On a practical front the change is likely to result in a need to revisit the design of impairment models, which could be a significant exercise for some societies. The new disclosure requirements could require the capture of additional information that is not currently reported within some societies. The increased disclosure requirements will increase the level of publicised information relating to the quality of mortgage books, which will have clear commercial implications.

Classification of financial assets – goodbye to AFS

The change in the classification rules for financial assets will have a material impact on some societies, resulting in increased income statement volatility.

The principal change that has been proposed is the removal of the AFS category. This currently enables certain debt and equity instruments to be held at fair value, with gains and losses being reflected in equity to the extent that they are not permanent impairments. Following the removal of this category, any assets within it will need to be reclassified as either Amortised Cost or FVTPL.

The use of the Amortised Cost category will be restricted to those instruments that are not traded, have basic loan features, and are held by the entity with the business objective of collecting its contractual cash flows rather than though disposal. In addition, the contractual cash flows of the financial asset must relate solely to payments of principal and interest on principal outstanding.

Where debt previously classified as AFS cannot be reclassified as Amortised Cost, it will need to be included in the FVTPL category with all fair value gains and losses being reflected in the income statement.

The treatment of equity instruments that are held as AFS will depend on whether or not they are held for long-term strategic reasons. Where this is the case it is likely they can be classified as Fair Value Through Other Comprehensive Income, with all gains and losses being reflected in equity, including impairments, and with no recycling through the income statement. Equity instruments that do not meet this criterion will need to be accounted for as FVTPL assets.

Hedge accounting – some positive news

The proposed model is principle based, and is designed to more closely align hedge accounting with risk management activities undertaken by businesses when hedging their financial and non-financial risk exposures. It should be noted that the proposals do not yet include portfolio hedging, which will be the subject of a further ED in 2011.

The ED moves towards a new hedge accounting model which combines a management view that aims to use information produced internally for risk management purposes, and an accounting view that seeks to address risk management in the timing of recognition of gains and losses.

The proposals of the ED include:

  • A move away from quantitative effectiveness measures, such as the 80 – 125% effectiveness criteria, towards a model in which there simply needs to be more than an accidental level of offset, although the latter is yet to be defined.
  • Extending the use of hedge accounting to net positions to improve the link to risk management.
  • The removal of retrospective effectiveness testing, albeit that prospective testing is still required and ineffectiveness will still need to be measured.
  • Fair value hedge accounting being reflected in reserves.
  • New disclosure requirements that focus on the risks being hedged, how those risks are being managed, and the effect on the financial statements of hedging those risks. Certain existing disclosure requirements will change, for example fair value hedge adjustments will be disclosed separately rather than being offset against the hedged item.

Don't wait too long

The new approach to impairment accounting will almost certainly reduce capital and could dampen future profitability. Meanwhile changes to financial asset accounting are likely to increase income statement volatility. However, the changes to hedge accounting may be more helpful in reducing volatility.

Fundamentally this is not just an accounting issue – there will be real commercial impacts and our key message is that these need to be factored into business and capital planning. There will be practicality issues relating to modelling and data capture and these will need to be identified and addressed in advance. There is still a reasonable amount of time to implement the new standard, but don't underestimate the challenge.

To read this article in full please click here.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

To print this article, all you need is to be registered on

Click to Login as an existing user or Register so you can print this article.

In association with
Related Video
Up-coming Events Search
Font Size:
Mondaq on Twitter
Register for Access and our Free Biweekly Alert for
This service is completely free. Access 250,000 archived articles from 100+ countries and get a personalised email twice a week covering developments (and yes, our lawyers like to think you’ve read our Disclaimer).
Email Address
Company Name
Confirm Password
Mondaq Topics -- Select your Interests
 Law Performance
 Law Practice
 Media & IT
 Real Estate
 Wealth Mgt
Asia Pacific
European Union
Latin America
Middle East
United States
Worldwide Updates
Check to state you have read and
agree to our Terms and Conditions

Terms & Conditions and Privacy Statement (the Website) is owned and managed by Mondaq Ltd and as a user you are granted a non-exclusive, revocable license to access the Website under its terms and conditions of use. Your use of the Website constitutes your agreement to the following terms and conditions of use. Mondaq Ltd may terminate your use of the Website if you are in breach of these terms and conditions or if Mondaq Ltd decides to terminate your license of use for whatever reason.

Use of

You may use the Website but are required to register as a user if you wish to read the full text of the content and articles available (the Content). You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these terms & conditions or with the prior written consent of Mondaq Ltd. You may not use electronic or other means to extract details or information about’s content, users or contributors in order to offer them any services or products which compete directly or indirectly with Mondaq Ltd’s services and products.


Mondaq Ltd and/or its respective suppliers make no representations about the suitability of the information contained in the documents and related graphics published on this server for any purpose. All such documents and related graphics are provided "as is" without warranty of any kind. Mondaq Ltd and/or its respective suppliers hereby disclaim all warranties and conditions with regard to this information, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. In no event shall Mondaq Ltd and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use or performance of information available from this server.

The documents and related graphics published on this server could include technical inaccuracies or typographical errors. Changes are periodically added to the information herein. Mondaq Ltd and/or its respective suppliers may make improvements and/or changes in the product(s) and/or the program(s) described herein at any time.


Mondaq Ltd requires you to register and provide information that personally identifies you, including what sort of information you are interested in, for three primary purposes:

  • To allow you to personalize the Mondaq websites you are visiting.
  • To enable features such as password reminder, newsletter alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our information providers who provide information free for your use.

Mondaq (and its affiliate sites) do not sell or provide your details to third parties other than information providers. The reason we provide our information providers with this information is so that they can measure the response their articles are receiving and provide you with information about their products and services.

If you do not want us to provide your name and email address you may opt out by clicking here .

If you do not wish to receive any future announcements of products and services offered by Mondaq by clicking here .

Information Collection and Use

We require site users to register with Mondaq (and its affiliate sites) to view the free information on the site. We also collect information from our users at several different points on the websites: this is so that we can customise the sites according to individual usage, provide 'session-aware' functionality, and ensure that content is acquired and developed appropriately. This gives us an overall picture of our user profiles, which in turn shows to our Editorial Contributors the type of person they are reaching by posting articles on Mondaq (and its affiliate sites) – meaning more free content for registered users.

We are only able to provide the material on the Mondaq (and its affiliate sites) site free to site visitors because we can pass on information about the pages that users are viewing and the personal information users provide to us (e.g. email addresses) to reputable contributing firms such as law firms who author those pages. We do not sell or rent information to anyone else other than the authors of those pages, who may change from time to time. Should you wish us not to disclose your details to any of these parties, please tick the box above or tick the box marked "Opt out of Registration Information Disclosure" on the Your Profile page. We and our author organisations may only contact you via email or other means if you allow us to do so. Users can opt out of contact when they register on the site, or send an email to with “no disclosure” in the subject heading

Mondaq News Alerts

In order to receive Mondaq News Alerts, users have to complete a separate registration form. This is a personalised service where users choose regions and topics of interest and we send it only to those users who have requested it. Users can stop receiving these Alerts by going to the Mondaq News Alerts page and deselecting all interest areas. In the same way users can amend their personal preferences to add or remove subject areas.


A cookie is a small text file written to a user’s hard drive that contains an identifying user number. The cookies do not contain any personal information about users. We use the cookie so users do not have to log in every time they use the service and the cookie will automatically expire if you do not visit the Mondaq website (or its affiliate sites) for 12 months. We also use the cookie to personalise a user's experience of the site (for example to show information specific to a user's region). As the Mondaq sites are fully personalised and cookies are essential to its core technology the site will function unpredictably with browsers that do not support cookies - or where cookies are disabled (in these circumstances we advise you to attempt to locate the information you require elsewhere on the web). However if you are concerned about the presence of a Mondaq cookie on your machine you can also choose to expire the cookie immediately (remove it) by selecting the 'Log Off' menu option as the last thing you do when you use the site.

Some of our business partners may use cookies on our site (for example, advertisers). However, we have no access to or control over these cookies and we are not aware of any at present that do so.

Log Files

We use IP addresses to analyse trends, administer the site, track movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.


This web site contains links to other sites. Please be aware that Mondaq (or its affiliate sites) are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of these third party sites. This privacy statement applies solely to information collected by this Web site.

Surveys & Contests

From time-to-time our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose any information requested. Information requested may include contact information (such as name and delivery address), and demographic information (such as postcode, age level). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the functionality of the site.


If a user elects to use our referral service for informing a friend about our site, we ask them for the friend’s name and email address. Mondaq stores this information and may contact the friend to invite them to register with Mondaq, but they will not be contacted more than once. The friend may contact Mondaq to request the removal of this information from our database.


This website takes every reasonable precaution to protect our users’ information. When users submit sensitive information via the website, your information is protected using firewalls and other security technology. If you have any questions about the security at our website, you can send an email to

Correcting/Updating Personal Information

If a user’s personally identifiable information changes (such as postcode), or if a user no longer desires our service, we will endeavour to provide a way to correct, update or remove that user’s personal data provided to us. This can usually be done at the “Your Profile” page or by sending an email to

Notification of Changes

If we decide to change our Terms & Conditions or Privacy Policy, we will post those changes on our site so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of an email. Users will have a choice as to whether or not we use their information in this different manner. We will use information in accordance with the privacy policy under which the information was collected.

How to contact Mondaq

You can contact us with comments or queries at

If for some reason you believe Mondaq Ltd. has not adhered to these principles, please notify us by e-mail at and we will use commercially reasonable efforts to determine and correct the problem promptly.