UK: Reviewing and Revising Corporate Interim Reporting - The half-time results

Last Updated: 1 March 2005
Most Read Contributor in UK, August 2017

Executive summary

It is a truth that nothing in company reporting is simple these days.

The above statement reads like an exam question to be followed by the word "discuss". For those studying what is happening in UK corporate interim reporting, the case for the affirmative answer is powerful. Two major changes are about to happen:

  • the EU’s Transparency Directive has to be introduced into UK regulation; and
  • as part thereof, companies will have to comply with the International Accounting Standards Board’s standard, IAS 34 Interim Financial Reporting.

The key findings in this work are:

  • the Transparency Directive’s requirement for the half-yearly results to be published within two months of the period end will affect 38% of listed companies who currently report in the third month after the period end. UK companies’ speed of reporting has improved from 51% taking over two months in 2002 to only 38% in the past 2004/5 season;
  • 46% of companies produced only six-monthly and annual performance numbers. The others produced a variety of reports from formal quarterly reports and monthly reports from the investment trusts to one ad hoc trading statement. Thus, apart from the 21% of monthly and quarterly reporters, the remaining 79% will be hit by the burden in the Transparency Directive of producing at least two "interim management statements";
  • the explanatory narrative sections within the half-yearly reports will require significant attention to ensure that the detailed requirements in the Directive are met. Of particular interest will be the need to focus on the principal risks and uncertainties for the remaining six months of the year and to report on major related party transactions; and
  • while segmental information is more frequently given by the largest companies, overall 50% of companies currently provide no segmental analysis within their financial information. Of course, some may have only one business segment. But it is likely that a significant percentage will be affected by IAS 34’s requirements for such information.

The rules of interim reporting and survey objectives

The requirements for accounting information to be provided in interim reports are set out in the Listing Rules of the Financial Services Authority, which require that:

"A company which has listed shares must prepare a report, on a group basis where relevant, on its activities and profit or loss for the first six months of each financial year."

These interim reports act as a progress report in the continuing reporting process, fulfilling a confirmatory and predictive function. Interim reports should enable users to monitor the progress of a business from its financial position as stated in the last set of annual financial statements and to assess the impact of recent events and developments on operating performance and financial position.

Only five years ago all that was required in interim reports were some profit and loss account numbers and a short explanation. For periods commencing on or after 23 December 1999, companies also had to provide a balance sheet and a cash flow statement. This change to the Listing Rules incorporated the main recommendations set out in a non mandatory Statement on Interim Reports produced by the Accounting Standards Board in 1997. That Statement remains extant to this day.

The UK Listing Authority (UKLA) will make further changes over the next two years as it will be obliged to implement the EU Transparency Directive. This Directive was finalised on 15 December 2004 and member states are required to comply with it by 20 January 2007. Proposals from the UKLA on its intentions for implementing this Directive are expected later this year.

For the half-yearly financial reports there will be a number of changes. These include the following.

  • The reports must be published within two months of the period end.
  • The companies concerned will have to ensure that the reports remain publicly available for at least five years.
  • Those responsible within the company for the half-yearly report must make a statement therein to the effect that:

"to the best of their knowledge, the condensed set of financial statements which have been prepared in accordance with the applicable set of accounting standards gives a true and fair view of the assets, liabilities, financial position and profit or loss of the issuer, or the undertakings included in the consolidation as a whole…, and that the interim management report includes a fair review of the information required…".

  • The interim management report, which is the explanatory narrative section of the half-yearly report, has to include not only a report on events that occurred during the first six months of the year but also a description of the principal risks and uncertainties for the remaining six months of the financial year and a report on major related party transactions.
  • If the company is caught by the 2002 EC Regulation on reporting under International Accounting Standards then the financial information in the half-yearly report must be prepared in accordance with the relevant standard on interim financial reporting, which is currently IAS 34.

Compliance with IAS 34 will create more changes for UK reporters. Those changes include the following.

  • Present UKLA rules require that the comparative balance sheet is that at the previous interim date. In other words, if an interim report is to 30 June 2005 then it is the balance sheet at 30 June 2004 that must be given as the comparative information. IAS 34 requires that the balance sheet at the end of the immediately preceding financial year, namely December 2004 in the above example, must be given.
  • The segmental revenue and results for the business or geographical segments used as the company’s primary basis of reporting in its annual financial statements must be given in the half-yearly report.
  • Detailed disclosures on for example major acquisitions or disposals of subsidiaries, changes in estimates or contingent liabilities or contingent assets, changes in equity statements and so on are required by IAS 34. Appendix 1 to this report sets out a disclosure checklist covering the present requirements and highlighting the additional rules from IAS 34.

A further change in the reporting landscape is that the Companies (Audit, Investigations and Community Enterprise) Act 2004 has extended the remit of the Financial Reporting Review Panel (FRRP) so that interim reports are now caught. In a recent press notice, the FRRP stated that "in 2005 the Panel will pay particular attention to interim reports with a view to identifying companies whose year-end accounts are expected to be subject to significant changes following the adoption of international accounting standards from 1 January 2005".

It is in the context of all these new rules coming into force over the next two years that this survey of current corporate interim reporting practice was carried out.

The main objectives of this survey were to consider:

  • what information companies provide in their interim reports;
  • how disclosure may vary depending on the size of the company;
  • how promptly companies are reporting and what means they use to publish the reports;
  • how the findings on current corporate interim reporting compare to the results of previous surveys undertaken in 2002, 1999 and 1995; and
  • the impact of adopting IAS 34, the international accounting standard on interim reporting.

To determine current practice, the interim reports of 100 listed companies, published in 2004/5, were obtained. The sample is, as far as possible, consistent with that selected at random and used in previous surveys. Because of the recent trend of delisting and the reduction in the number of UK listed companies, the sample could not be identical. 75 of the companies surveyed in 2002 were still fully listed in 2004/5. 10 of these companies did not have interim dates that matched our 2004/5 selection criteria, so 65 companies in our 2004/5 sample were also surveyed in 2002.

35 additional companies were selected for the 2004/5 survey, based on market capitalisation to provide a final population stratified into three categories; companies within the top 350 companies by market capitalisation, those companies ranking 351-965 by market capitalisation and the third category of smallest 350 companies by market capitalisation. As a result of the significant reduction in the number of fully listed UK companies, the three categories listed above had to be amended from the categories used in the 2002 survey to ensure a sufficiently large population within the third category. Not surprisingly, the top 350 list of companies looks most similar to the equivalent list from the 2002 survey.

The mechanics of reporting

In view of the constant demand by stakeholders for faster, more reliable and more extensive reporting, this section examines to what extent interim reports meet these demands, including:

  • the speed of publication of interim reports;
  • quarterly reporting;
  • the level of involvement of auditors when preparing interim reports;
  • the mode of delivery including e-reporting; and
  • the visual style and extent of the interim report.

Speed of reporting

Companies are required by the Listing Rules to report their interim results within 90 days of the period end. The ASB Statement is more stringent and recommends the interim report be produced within 60 days.

Companies take on average 55 days to report (2002: 61 days). All companies in the sample reported within 90 days, although three companies took exactly 90 days to report. 38 companies failed to meet the 60 day deadline recommended by the ASB compared to 51 companies in 2002, of which eight were companies in the top 350 (2002: 15). The 14 companies reporting within 30 days were relatively evenly spread across the three categories.

In its December 2004 newsletter "List!", the UK Listing Authority referred to its option to extend the 90 day publication deadline, for the first interims prepared using IFRS, to 120 days in line with current European legislation. However, the Transparency Directive 2004/109/EC of the European Parliament and the European Council, which has been published in the Official Journal late in 2004, will require that half-yearly reports should be made public at the latest two months after the period end. This is currently expected to come into force in the UK in 2006/7.

Companies are now reporting more quickly than in previous years, following an insignificant change in reporting speed between 1999 and 2002.

The ASB Statement recommends that the date on which the report is approved by the board of directors is disclosed. In the 100 interim reports surveyed, there were five instances in which there was no obvious indication of the date of publication. For these companies, the date of publication has therefore been derived from other information sources such as press releases. In one instance, the board only reviewed but did not explicitly approve the interim information, as recommended by the ASB Statement.

Quarterly reporting

A number of companies issue quarterly statements or trading updates, either voluntarily or as a result of dual listings. In most cases quarterly statements are produced as separate statements in addition to the half-yearly report. Of the 100 companies surveyed, 13 made quarterly trading statements available on their websites. Ten companies produced a quarterly statement for only the first or the third quarter, on an ad hoc basis to explain significant events or transactions. In eight cases, all of which were investment trusts, monthly fact sheets containing information about financial performance and position were available online. 23 companies prepared pre-close trading updates for their interim and/or annual results, but no quarterly information. 46 of the 100 companies surveyed did not produce trading updates in addition to their interim and annual reports.

Only one interim report contained quarterly information in addition to the cumulative six month figures.

As mentioned earlier, the Transparency Directive is expected to come into force in 2006/7. The Directive contains the requirement for listed companies to issue at least two "interim management statements", one during the first half, and another during the second half, of the financial year. Such statements should contain:

  • an explanation of material events and transactions during the period and their impact on the financial position of the group; and
  • a general description of the financial position and performance of the group during the period under discussion.

Companies which prepare quarterly reports, either voluntarily or because of particular listings, are exempt from the requirement to prepare interim management statements. Based on the 2004/5 experience of quarterly reporting practice amongst UK listed companies, the requirements for interim management statements by the Transparency Directive will result in an additional reporting burden particularly for smaller companies, and more systematic reporting for others.

The auditors’ involvement

Since the 2002 survey, auditor involvement in the interim reporting process has fallen slightly overall. 49 of the companies surveyed showed evidence of auditor involvement, compared to 54 in 2002. Interestingly, the auditor involvement remains most widespread in the largest companies where the number of companies referring to auditor involvement has notably increased from 62% in 2002 to 79%. In contrast, in the smallest 350 companies auditors’ involvement has fallen from around 50% in 2002 to 30%.

The Listing Rules require that "where the figures in the halfyearly report have been audited or reviewed by auditors […], the auditors’ report should be reproduced in full". No company in the survey went to the extent of having its interim report audited in full. 49% (2002: 54%) of companies had a review performed and reproduced the review report as required.

Of the 51 companies that did not include a review report in their interim statements, only 12 companies stated explicitly that the interim information had been neither audited nor reviewed. The majority of the remaining companies stated only that the interim information was unaudited. The Transparency Directive will introduce a rule in this area. If the interim report has not been audited or reviewed by auditors, the company must make a statement to that effect in its report.

Mode of delivery

The Listing Rules require a company either to "send the half-yearly report to the holders of its listed securities; or insert the halfyearly report, as a paid advertisement, in at least one national newspaper". It was not always clear from the report or other company information such as press releases, which companies have sent copies of the interim reports to shareholders and which published in a national newspaper. Of the companies surveyed, at least 52 companies sent out their interim report.

Companies increasingly use the Internet as a means to communicate quickly and cheaply with their shareholders. 80% of the companies surveyed had published interim information on their company websites.

As expected, web reporting is more common in the larger companies. Of the companies surveyed, only did not appear to have a website, all of which were in the smallest 350 companies.

Visual style and extent

There was a wide range of styles and extents of interim reports. Some companies produced mini-annual reports, up to 62 pages long, providing extensive commentary and detailed information to capture their shareholders’ and investors’ interest and to communicate effectively on the development and performance of their companies. In contrast a small number of companies continue to produce typescript documents of as little as three pages (excluding one page newspaper adverts) that merely seek to comply with the minimum Listing Rules requirements.

The average number of pages contained in the interim reports surveyed, excluding one page newspaper adverts, was 13 pages. Probably unsurprising, the average length of the interim report overall varies according to the size of the company.

The explanatory narrative

The Listing Rules require half-yearly reports to contain "an explanatory statement which includes:

(a) any significant information enabling investors to make an informed assessment of the trend of the group’s activities and profit or loss;

(b) an indication of any special factors which have influenced those activities and the profit or loss during the period;

(c) enough information to enable a comparison to be made with the corresponding period of the preceding financial year; and

(d) so far as possible, a reference to the group’s prospects in the current financial year".

The explanatory statement gives the opportunity for management to place their results in context, outline the activities of the group during the period and convey their thoughts on what the future might hold for the group. In difficult times the narrative can be used to explain and justify decisions which the board has taken and to update on the progress made.

This section examines:

  • the author of the explanatory narrative;
  • its length; and
  • the contents.

Who makes the commentary?

While commentary is mostly presented in one main section, 28 of the companies surveyed provide more than one section. In some cases, there was a short statement by the Chairman, followed by a more detailed commentary from one or more other directors. Overall the Chairman remains the main commentator in interim reports.

The results show that:

  • in 64 interim reports the Chairman was the main author of the commentary whereas the Chief Executive was the main commentator in only eight cases. Included in these numbers are cases where there was only one report. In these cases, the Chairman was sole commentator in 52 interim reports and the Chief Executive in two cases;
  • in one instance the chairman and chief executive was one person;
  • in 16 interim reports the commentary was provided by both the Chairman and the Chief Executive, six of which were in combined, and ten in separate, sections;
  • six interim reports also included a commentary by the Finance Director, together with the commentary by the Chairman (2), the Chief Executive (3) or both (1);
  • in one report the company secretary provided the commentary, as did the board of directors in another company;
  • in nine interim reports, the author of the commentary was not identified. Two of these reports contained quotes from the Chief Executive, but no signature. Of the unidentified reports, eight were in the top 350 category;
  • a further nine reports included additional sections for which the authors were not identified; and
  • in one instance only highlights were given but the report did not contain an explanatory commentary as such.

This is an area in which there is likely to be a change in practice, following the introduction of the Transparency Directive. While it does not detail who must give the "interim management report" as it calls the explanatory section, it requires a confirmatory statement, from those responsible for the management report, to the effect that the report gives a fair review and that the condensed set of financial statements gives a true and fair view of the group’s assets, liabilities, financial position and profit or loss. The names and functions of those taking these responsibilities must be clearly identified.

How long is the commentary?

The length of the narrative varies extensively. Following the increase of the number of words since the first survey in 1995 up to 2002, the trend is now reversing. The length of the commentary has reduced in favour of shorter commentaries below 500 words. This finding is consistent with the message that emerged from a recent Deloitte survey on annual reporting.

Content of commentary

The content and quality of the commentary given was found to be as varied as its length.

The vast majority of the companies surveyed (96%) made some attempt to discuss the significant events and trends in the interim period. 83% of the companies sought to provide more helpful and useful information by putting the company’s results into the context of the industry and general economy (2002: 77%). However, the quality of comments made here was variable, ranging from a detailed analysis of the company’s activities and the industry in which it operated, to bland comments on the state of the economy. A few examples follow.

"The economy has slowed in the last quarter but we remain well placed to continue to build on our success."

"Overall, we believe that the Group is on track to meet market forecasts for the full year and, in the absence of unforeseen circumstances, we would expect to maintain the level of final dividend paid last year."

More incisive comments are not necessarily lengthy. The following seek to explain industry developments and their impact on performance.

"Corporate rumour and speculation continue to abound in this sector, where further consolidation is perhaps overdue, and competition for the attraction and retention of competent staff remains fierce, often to the advantage of only the legal profession. However we will continue to nurture and protect our recognised areas of niche excellence, and our balance sheet strength: therefore my cautiously confident view of the longer term future is undiminished."

"Oil refining capacity is fully utilised and refinery throughputs are at maximum levels in many countries, particularly the US. Consequently the industry is experiencing the highest margins for many years. This environment provides many opportunities to utilise our technology and experience to increase refining capacity while respecting environmental constraints and to develop cohesive site-wide energy conservation strategies. […] We expect these opportunities to translate into stronger demand for our improved services and software next year as clients utilise higher profits to optimise operations."

The following comments were enjoyable.

"The rise in benefit claimants and the compensation culture are two more unholy hags that bode badly for our economy in the months ahead. Their malicious allies are the looming iceberg of the private sector pension deficit and the rising cost of raw material, especially oil. We learn that the price of West End property is being inflated by the demand from Hedge Funds and Government Agencies. Whilst it is reasonable for the investors in the former to pay for the proximity to Purdey’s and Wilton’s, it is baffling to the point of incomprehension why the Curriculum and Qualifications Agency or its ilk needs to occupy a prime position on Piccadilly; particularly if […] can thrive in the obscurity of Isleworth; the gravy train of government contracts ultimately seeps out of the productive pockets of the tax payer."

The ASB Statement on Interim Reports recommends that the following bold matters should be discussed in the commentary, so that the user can make an informed assessment of the company’s financial position and performance. The survey findings on these matters are also summarised.

  • Reference to the company’s prospects in the current financial year – in many cases this remains often no more than a couple of sentences at the end of the commentary.
  • Information on perceived trends – this should include information such as an indication of the company’s plans for the future, any major uncertainties or the possible effects on the annual result. 13% of interim reports did not contain such information.
  • Treasury analysis – only 10% of the companies surveyed provided a meaningful, added value financial review or treasury analysis. 31% of companies merely gave a factual discussion on the balance sheet. The remaining companies did not include some sort of treasury analysis.

To continue reading this article 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 Mondaq.com.

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

 
In association with
Related Video
Up-coming Events Search
Tools
Print
Font Size:
Translation
Channels
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
Password
Confirm Password
Position
Mondaq Topics -- Select your Interests
 Accounting
 Anti-trust
 Commercial
 Compliance
 Consumer
 Criminal
 Employment
 Energy
 Environment
 Family
 Finance
 Government
 Healthcare
 Immigration
 Insolvency
 Insurance
 International
 IP
 Law Performance
 Law Practice
 Litigation
 Media & IT
 Privacy
 Real Estate
 Strategy
 Tax
 Technology
 Transport
 Wealth Mgt
Regions
Africa
Asia
Asia Pacific
Australasia
Canada
Caribbean
Europe
European Union
Latin America
Middle East
U.K.
United States
Worldwide Updates
Check to state you have read and
agree to our Terms and Conditions

Terms & Conditions and Privacy Statement

Mondaq.com (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 www.mondaq.com

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 Mondaq.com’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.

Disclaimer

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.

Registration

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 unsubscribe@mondaq.com 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.

Cookies

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.

Links

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.

Mail-A-Friend

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.

Security

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 webmaster@mondaq.com.

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 EditorialAdvisor@mondaq.com.

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 enquiries@mondaq.com.

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