UK: Managing Sickness Absence (Video)

Managing sickness absence can be tricky, costly and time-consuming for businesses. As the majority of the workforce starts to return to the workplace, the COVID-19 pandemic will throw up new challenges for employers to grapple with when it comes to managing absences. In this session, partner Jane Fielding and principal associate Emma Bufton cover how businesses can best equip themselves for these new challenges and tips on managing short and long-term absences with a particular focus on COVID-19 related absences.

Transcript

Jane Fielding: Good morning. My name is Jane Fielding. I am head of the employment labour and equalities team here at Gowling WLG in the UK and I am delighted to welcome all of you to our webinar this morning on managing sickness absence. I am joined by Emma Bufton who is one of the principal associates in our team and who has recently returned from a six month secondment at a client where she has regularly been advising HR and the business on these sorts of issues.

Now sickness absence is a perennial challenge for employers resulting in loss of productivity, impact on staff morale, time, cost etc. and you might have thought that during the pandemic days lost to sickness absence would have gone up. In fact, according to figures from the Office or National Statistics, the average number of days per employee per year lost to sickness actually went down from 4.4 in 2018 to 3.6 in 2020. Now that could be for a range of reasons. It could be people living healthier when working from home, more exercise, better diet, lack of mixing, or it could be a lack of reporting due to fear of redundancy perhaps. But whatever the reason as we all begin to mix more and people are bringing their staff back to the workplace perhaps for the first time, we are seeing more sickness issues coming to the fore and so we thought it was a good time to do a refresher on this topic.

So what we are going to cover on the agenda is a brief view of the legal landscape which Emma is going to give. Policies, training and monitoring and how important those are and then with reference to some scenarios which we have given a COVID flavour we are going to look at how to manage short term persistent absences and long term absences.

Now we are going to speak for about 30 minutes and then we will leave time at the end for some questions before we close at 11.55am. Now if you could use the Q&A function which is if you are not familiar with Zoom, at the bottom middle of your screen. If you just type a question if you have one into there, and we will keep an eye on those as we go along and as I say we will try to get to as many as we can before the close. If we do not answer your question and you put your name on it rather than anonymous then we will follow up with you afterwards so you will get a reply. If you have got any tech issues then if you also use the Q&A function then Joy Litchfield who is helping us with the tech today will try to sort that for you, and at the end we will send by email a feedback questionnaire which we would be really grateful if you could fill in. We do read them and we do take account of them going forward. So I will hand over to Emma.

Emma Bufton: Thanks Jane. So if we start off then by looking at the legal landscape I think it can sometimes be forgotten that there is no actual statutory right to take time off for sickness or injury. In most cases though employees will either have that written into their employment contracts and that is because of section 1 of the Employment Rights Act, which requires terms and conditions on sickness to be contained in either the contract or some other document or policy that is reasonably accessible to the employee or it is very likely to be arguable that ought to be an implied term that the employee is not required to work if they are not well enough to do so.

Whilst there is no expressed statutory right to sick leave, there is an expressed statutory right to sick pay so all employees if they meet the eligibility criteria are entitled to statutory sick pay for up to 28 weeks if they are absent on grounds of ill health or incapacity and the current rates for that are £96.35 per week. Ordinarily and I will come on to explain some exceptions to this, this is available only after the employee has been absent for three consecutive days so it is available from day 4. If the employer choose to do so, they can offer to enhance statutory sick pay. If they are going to do that, then that should be clearly set out in writing and also that should for instance things like whether or not that company's sick pay is discretionary and also whether or not any statutory sick pay is going to count towards company sick pay.

Now the COVID pandemic has led to a series of changes to the statutory sick pay regime and those came into force in March last year. These are as you would imagine technical and complicated but broadly there are three changes. The first is that employees who are self-isolating or shielding are permitted to access statutory sick pay and there has also been a removal of the need for waiting days in COVID 19 cases. So that requirement to wait three days before you can access statutory sick has gone and that is for policy related reasons that the Government wanted to make sure there were not any barriers to doing the right thing and encouraging employees to self-isolate.

The final change is that those employers who have fewer than 250 employees are entitled to recover from HMRC up to two weeks SSP per employee for COVID related absences. Whilst technically there does not appear to be an end date for these regulations there was initially and that was subsequently removed. It seems likely that these provisions will expire around about the same time that other employment COVID related regulations will expire so both the self-isolation regulations and the Coronavirus Act itself both expire on 24 March 2022 so it seems likely that the statutory sick pay regulations will be around until at least then.

So there are a number of pitfalls and potential claims for employers to negotiate when they are navigating and managing that sickness absence process. Now for timing reasons we are not going to be able to look at all of these in any great detail and delve into the law and tests on them. What we wanted to do at this stage was to flag them to you so that they are on your radar and so the first to those that you will see on the slide is unfair dismissal and that is both ordinary unfair dismissal and also constructive unfair dismissal risks when managing sickness absence. So if the employer were to unreasonably refuse to permit their employee time off if they are ill and that employee were then to resign and claim a fundamental breach and breakdown of the relationship. That could rise to a constructive unfair dismissal risk and also if the employer were to decide that the employee's level of absence were no longer tolerable and were then to move to terminate that employment, that could give rise to unfair dismissal risks.

For these claims, employees need to have two years' service and to mitigate against the risks because capability is one of five fair reasons for dismissal, the employer must make sure that it follows a fair process and crucially that a decision is reasonable in all the circumstances so dismissal really should be the last resort.

The second potential pitfall on the slide is discrimination. Now of course not all disabilities lead to increased absences, but if an employee who has been absent from work for a reason related to illness might be protected by disability discrimination under the Equality Act. There is no minimum qualifying length of service and also no upper limit on compensation in the same way there is with unfair dismissal claims. If employers are in any doubt on this, it is best practice to err on the side of caution and treat the employees if they are disabled.

The third potential pitfall is breach of contract and that is particularly an issue for employers whose policies and procedures are contractual because if they are not followed to the letter then there is a breach of contract risk.

There is also a risk of health and safety and working time regulation risks and that has really risen to the forefront since the pandemic. It used to be very rare for us to see section 100 Employment Rights Act related claims, so those claims for automatic unfair dismissal for health and safety related breaches. We have now seen much more of those and also with the rise in remote working that followed as a result of the pandemic, many employers are continuing to offer that flexibility to employees. So they are going to need to be alive and mindful of the impact that these different working patterns might have the possible increases of stress that can bring for employees trying to balance home and working life and also that can lead to increased working hours.

Fifthly, there might also be a rise in personal injury claims. I mean the obvious one being if an employee sustains an injury whilst at work. But also we have seen a rise in stress related claim if they say that that particular illness has been caused by work or the workplace. The last one, the last pitfall to flag before I hand back to Jane is that as well as PR damage, managing absence can also be an employment relations issue too. Jane mentioned about absence having an impact on employee's colleagues and their morale if they have got to pick up the slack but it is also an opportunity for employers if the absence management is managed well for employees to have confidence that they are working in a supportive and collaborative organisation. OK I will pass over to Jane.

Jane: So having a policy to manage sickness absence, training your managers on it and keeping track of the absence is really key for two reasons. Firstly, planning for the worst so you are building your defence to a tribunal claim in the event that you end up with one of those and it does not remain internal. Secondly, you are sort of hoping for the best with a good process and support to the employees, hopefully they can improve their attendance and/or performance at work.

Though a procedure is something that a tribunal certainly in any organisation of any size will expect to see. It is also important for your employees' relation perspective so that employees can see that there will be fairness between them. A good policy can help managers understand what their role and responsibilities are and it allows employees on the other hand to sort of manage their expectations about how their sickness absence will be handled and what they can expect to be looking at. So many of you will have a policy already I would expect but just a reminder or if you do not have one already, as a minimum you should have the following in there. So setting out what the obligations are employees to report their sickness absence and what evidence you are going to require from them of the fact they cannot come to work. You are also going to have to put in there something about sick pay so as Emma said that could be statutory or company sick pay and that might also be in the employment contract but it is worth having it in the sickness absence policy as well. Really important and quite often forgotten to be implemented in practice but you should have it in your policy are return to work interviews. So when somebody comes back sometimes it is very easy for the line manager to think right well job done, they are now back working, but it is really important that they remember to have that conversation with staff when they are returning.

The policy should set out the different processes for managing short term persistent absences, and long term absences which we will look at when we come on to the scenarios in a little while.   Finally it should make clear in what circumstances you might ask employees to go for a medical examination or provide further medical information about their condition.

In terms of training line managers are very often going to be the first sort of line of contract for staff. They are the ones who are going to receive the sick calls, they know their staff best, they know and understand the impact on the team if somebody is going to be off. So it is really important they understand your policies and procedures so they know what to do when they are in this sort of situation. Now obviously HR and in-house legal can help but, as I say the primary responsibility for managing this is going to fall on the day to day line managers, and the training should not just cover the process but it should also cover the need to deal with these sorts of situations with a degree of empathy and humanity. Now it may sound odd to have to point that out in training, but I am sure we have all seen situations where it comes to us when it has all gone wrong and we look back at how it started and think well if anything the manager had been slightly more sympathetic to be begin with. Then we may not have ended up here.

So support from managers can be a really positive experience and it can really help resolve the situation. So it also is important that managers understand at what point they can be talking to the employee about getting some medical evidence and getting some information about what the condition is that is keeping them off work. In particular if it a short term persistent absence situation they need to understand at what point it is appropriate for them to say to the employee well look are you actually getting some medical advice and some help with this because there might be an underlying issue that could be addressed and that could see you delivering a better performance.

Now one thing I wanted to flag here is the training absolutely needs to cover the managers' obligations under the GDPR, the data protection obligations. Wherever you are dealing with health information, that is special category data under the GDPR so there are extra safeguards in terms of processing it and that is particularly important where information might be being shared between departments so between the managers and HR for example.

And in terms of monitoring. This is really important both at an organisational level and also in terms of individual cases so organisationally, having the data about your sickness levels will help you track the impacts, the cost of that absence, but also to see if there are any patterns in where the absence is occurring and what type. So it might be if you have a particularly high level of absence due to stress in a particular team. It could be an indicator that team is under resourced or it could be an indicator that is it being poorly managed, perhaps there is some bullying conduct going on there, so it helps you dig down deeper and try to resolve the issues at an organisational level.

Again you need to be very mindful of GDPR requirements even if they are doing it at an organisation level. The information might not be truly anonymous depending on the size of the team and the seniority of the people involved for example.

And on an individual level you really need to have a good paper trail of what you have done in terms of interacting with the employee as well as the actual absence themselves. As I said, a tribunal will expect to see this when they are looking back at how the situation is being managed. They will want to see contemporaneous evidence of that so it is really important that any interactions whether it is a meeting in the workplace, a home visit, telephone calls, WhatsApp messages. Whatever it is that they are all properly and accurately recorded, and of course on the proactive side having a clear record of the interactions will also make it easier particularly if you have got reminders of what the next thing to do is to actually manage it live at the time. So a more proactive approach. So I am going to hand over to Emma now.

Emma: Thanks Jane. So for this next section we are going to launch into a couple of scenarios on short term and persistent absences to try and bring this area a little bit more to life.

So this is the first of our scenarios and it is a scenario where you have an employee who is persistently off with short bouts of absence which appear on first blush to be unconnected and what you do in those scenarios. I think there can sometimes be some scepticism about the reason for someone's absence and it being genuine and that is particular the case for short term persistent absences. Employers do need though to be careful about making assumptions and jumping to conclusions based on a perception that an employee is never there. And that is one of the reasons why recording absences is so important. Not only to see if there is a pattern but also for identifying if any of those reasons are linked. Employers when looking at this should be looking at the pattern over a sensible period of time because that is going to build up a reliable picture of that individual's absence. A good way of doing that is to use a calendar showing absences as against attendance. Of course making sure that when you are looking at the absences, you are not including absences of a different nature such as someone being off on holiday or family friendly leave. That should help identify if there is a serious problem. After analysing the evidence over a period of time the next steps then is going to be to speak to the employee to gather further evidence and understand a little bit more detail about the reasons for their absence might be.

Of course you need to be mindful. Ensuring compliance with policies and procedures when you are doing this as Jane has already mentioned and that is going to be even more important if those policies and procedures are contractual but short term absence policies generally do involve a certain number of absences then going on to trigger when a return to work meeting will be held.

An employer should think carefully about what those triggers will be to make sure they are capturing not only continuous periods of absence but also those persistent and irregular absences too.

But if that formal return to work meeting has not been triggered that does not stop the line manager having an informal wellbeing catch-up with the employee if there are concerns.

So depending on what the employee says, and it might be that there is a conduct or capacity issue. If there is a capacity issue then you will want to investigate the medical issue through contact with that employee's doctor or with occupational health and it may be that you need more specialist advice depending on what the opinion of that GP or occupational health is and how conclusive it is. Do not be tempted to rely on old occupational health or doctor's reports because the position may well have changed. What you are really trying to establish with the medical evidence is what is the nature of the condition, are the absences connected, what level of absence can be expected in the future and how long is it expected to last?

You will also want to explore what steps can be taken that might reduce the risk of the employee's absence levels, and when you get that report back, do not delay on acting on it. What you do not want then is for that report to then become out of date. But on the slip side you do not want to be acting too quickly before you have had the report.

And the second element of this scenario is what happens if those seemingly unconnected bouts of absence turn out to be connected symptoms of some underlying mental or physical health issue. I think then if the evidence suggests that there is an underlying health issue, you will want to understand from either the GP or occupational health if there are any reasonable adjustments that you should be considering. That is because for disabled employees reasonable adjustments are a legal entitlement but even if that employee does not have a disability there may well be a strong duty of care or employee relations reasons for seeking to accommodate that if at all possible.

If the employer has given serious consideration to the alternatives, including looking at things like changing working patterns and redeployment for example. And if the medical prognosis is that that absence is likely to continue for a seriously disruptive level and a considerable period of time. Then it may be fair to dismiss but before dismissal there should have been appropriate escalation through warnings and that is one of the key differences between short and long term absences that Jane is going to come on to talk about in a few slides time.

If that employee is dismissed and the process has been followed. Then the employer is going to need to demonstrate that any unfavourable treatment arising from that employee's disability if they have got one, is justified as a proportionate means of achieving a legitimate aim. An examples of such justifications might include the nature of the work and the impact of that particular employee's absence on the business being such that it justifies it. You can see how that might arise in smaller organisations if for instance, you have got the managing director with persistent short term absences. It is going to be difficult to justify and a much more careful balancing act will need to take place for larger organisations where the employee might be at a mid-level junior level and whether a number of others doing the same job as that individual.

So if we move now then on to our second scenario and this is a scenario where an employee catches COVID but the only reason they caught COVID is because they failed to follow health and safety measures that their employer has put in place and what should you do in that scenario.

Well there are really two elements to consider here. So the first of those is the COVID related sickness absence and the second is the employee's failure to follow the correct measures. So if we look at sickness absence first if the employee as told their employer they have COVID then the starting position is that they must self-isolate for ten days. That means they must not leave their homes or the place where they are self-isolating even if they are feeling well enough to. If that individual were to come into the workplace and both the employer and the employee could face penalties under the self-isolation regulations and the levels of the fine there are between £1,000 and £10,000.

If the employee is unable to work or unable to work from home then they will be entitled at a minimum if they are eligible to statutory sick pay. As I mentioned earlier that is available to them from day one. If they are absent again the employer should be looking to record that and also the reason too.

It may be though that the employee is well enough to work and that they can work from home and in that case it would be prudent for the line manager to make sure that they are continuing to check in with the employee whilst they are off for duty of care related reasons.

So of the two that is the more straightforward process and would usually be dealt with under a sickness absence policy but what happens if the reason the employee has caught COVID is because they failed to follow health and safety measures that their employer has put in place. Well that may well trigger conduct and also health and safety policy breaches.

What we have had is the recent case of Kubilius and Kent Foods. That was an ET first instance decision so it will not be binding on other courts but it is interesting to see how the tribunal applied the law in this case and it is also useful for employers who have put in place those health and safety related measures and then have staff who have gone on to ignore them.

So on the facts of this case the claimant was a delivery driver and he was required to attend the customer's site to deliver goods and that customer required him to wear a mask. In his employee handbook it required him to obey all customer instructions regarding PPE requirements and he refused to wear the mask and had no exempted reason for doing that and so was banned by the customer from their site.

An investigation took place and the claimant was subjected to disciplinary proceedings and ultimately dismissed. Now when the tribunal looked at this it considered on these particular facts that because there were no other job that this individual could do and this key customer had refused to permit the employee to work on their site despite numerous attempts by the employer to persuade them to rescind the ban. There was also a requirement for all employees who were doing the same role as Mr Kubilius to work for that particular customer. The tribunal was able to find that there was no unfair dismissal in this case so I think the key takeaway here is that whilst dismissal may have been fair in this case whether it is going to be fair in others will depend on the facts and seriousness of the breach. Being dismissed for instance for accidentally failing to follow a one way system is unlikely to be a reasonable response but if on the other hand the employee has come into work when they have got COVID then clearly that is at the other end of the spectrum. What will be important is that the employer has a genuine belief in the misconduct, that they have carried out a thorough and reasonable investigation, and that any disciplinary sanction up to dismissal is reasonable in all the circumstances. OK I will pass back to Jane.

Jane: Thanks Emma. So long term absences, I think the first thing to say is here what do we mean by long term? So in the absence of somebody having a serious accident or going in for a serious operation which is clearly going to take them out for weeks or possibly months and you an plan to that to some extent, we recommend treating anything as long term if the employee has been away for ten working days. Now that may sound quite short but actually the sorts of common colds, flu's, stomach upsets etc. really should clear up within that time and we often see situations go wrong because the issue has not been addressed early enough. I guess like wine it does not improve with age. If somebody is off sick then you need to understand why and what you can do about it. Now in a long term sickness case, you also need to be mindful of the fact that the employee may be disabled. That may be the reason they are off sick, although of course just because somebody has a disability it does not necessarily mean that they are going to have higher levels of sickness absence at all. It very much depends on the nature of the disability but you need to understand that and you need to understand whether they have an existing health condition, sorry a health condition that is new but is exacerbating an existing disability. So for example somebody who suffers from anxiety if they have a diagnosis of a serious physical condition that may exacerbate their anxiety and they may need extra support to be able to return to work or to remain at work potentially during treatment.

So on the screen there, you have got the definition of disability from the Equality Act. An employee has to meet every part of that definition so what I would say is it a pretty low hurdle which is why as Emma said earlier unless it is very obvious such as a cancer diagnosis then we suggest that you work on the assumption that they are covered but do not admit that during the internal process. Only the tribunal ultimately can make a definitive finding as to whether somebody is disabled or not so when you are managing an internal process you have to proceed on the basis of assumptions and make it clear as I said.

Now the key to unblocking any situation of a long term sickness is to really understand what the issue is with the individual, what is keeping them off sick and you are really going to need medical evidence on that. So you want to understand the prognosis. How quickly will they be able to come back, will they be able to come back at all, is it a phased return with or without adjustments. Once you have got your medical advice from your employee's GP or perhaps their treating consultant for occupational health then as Emma said earlier what is really essential and again a very common pitfall here is not acting promptly enough on the evidence and then by the time you come to make a decision it has gone stale.

I also wanted to flag here that if you are going to be getting medical reports or information from the employee's treating physician so their GP or their consultant, then there are additional safeguards in terms of those reports in addition to consent, which you are always going to need if you are getting medical input.

So moving on to the first scenario is long term sickness. You have got somebody who has been off with Long COVID for several months. Now how do to you manage that? Well hopefully the line manager has been in fairly regular contact with them but as Emma said unlike in short term persistent absences where initially you may be thinking is it conduct, it is genuine sickness. Clearly there is an issue here that is genuinely sickness and warnings are not going to help. They key as I said earlier is understanding what the medical position is and the prognosis. Now with a condition like COVID which is newly emerging well with some other rarer and unusual conditions sometimes you will need to go to an independent specialist or the individual's own specialist. If they do not have one yet then finding the right person can be tricky so you do need to be mindful of that and factor that into dealing with the process.

Sometimes of course we see employees not being cooperative in getting that information. In that situation you need to be explaining to them that you really do need the full picture in order to make a fair assessment of the situation and try to persuade them that it is in their interests to let you have the report. They need to understand that if they do not, you will have to make a decision at some point on the information that you have available. Now the medical advice might come back and say that in a few weeks with some adjustments they can return to work. So in that case you agree a plan with them, you take notice of the medical advice and you implement that plan hopefully.

So what if the prognosis is unclear what if there are queries in the report that you want to go back on? Well you are perfectly entitled to follow up with questions if it is not clear. But sometimes it just will not give you the clarity that you need and you need to make an assessment on the basis of the information that you have. The point at which it is going to be fair and justifiable from a disability discrimination perspective to press the button and dismiss somebody is going to vary because it is going to be very fact specific but it will take into the sort of factors that Emma talked about in the short term scenario. So the size of the employer, the impact on the business etc. What I would say in terms of impact on the organisation, in some cases it will be very obvious and if you end up in a tribunal, a tribunal will accept at face value what you are saying that there was an obvious impact to get somebody very senior who is absent for many months for example. Do not assume that so in your internal process make sure that you are documenting and having it explained certainly in the final meeting with the employee if not before we dismiss what the impact is and why it is no longer sustainable for you.

The other really important thing before you make any decision to dismiss is to make sure that you have exhausted alternatives. Now that may be alternatives in the sense of there might be another job they could do. Perhaps they could got to part-time work, perhaps they could give us some element of their job temporarily or permanently and really importantly you need to look at whether you have got a permanent health insurance policy that they could benefit from or even ill health early retirement or other retirement options under your pension scheme. If you do not take those steps you are much more likely to lose the claim for it to be an unfair dismissal but it can also be a very expensive mistake particularly if you cut across a PHI policy with its very valuable benefits.

And moving on finally to the second and last scenario I can deal with this one much more briefly so here you have got somebody who has got a history of anxiety and depression and that is being exacerbated by your asking them to come back to the workplace after perhaps a very long period working from home exclusively.

So many of the considerations will potentially be the same but before you get into getting medical advice and all the things I talked about in terms of the first scenario the key here is really to have good communication and conversation with the employee to really try and understand what their concerns are? Is about the commute, they do not want to get on public transport. Is it about the COVID compliance measures in the office so you really need to understand what the concerns are because then you can start exploring with the employee collaboratively what you might be able to do to unpick them. So if it is a public transport concern maybe you can offer them staggered worktimes. They could come in later, lave earlier, whatever it is, make up the time at home. They could perhaps work from home part of the week, but unless you understand what it is that is driving the anxiety and the concern you can really come up with effective solutions and as I said eventually it may be that you need to kind of go back or progress to getting medical advice and try to unpick it that way.

So that is the end of the presentation. We have got time for a couple of questions or a few questions before we close.

Emma, I can see there is one here about asking about the new proposals that the Government has mentioned about sort of overhauling the SSP system. Do you want to pick that one up?

Emma: Yes sure. I think it is fair to say that the current legislation that we have got on SSP is complicated, cumbersome and not right for form to be honest. The Government has recognised that so the they did launch a consultation a couple of years ago now putting forward some helpful proposals of how to shape things up for statutory sick pay. So we are looking at things like simplifying the rules and widening eligibility requirements and also looking at things like enabling non-disabled employees to return to work on either a flexible or phased basis.

It took a couple of years for them to respond to that initial consultation and we did have the response this year. Unfortunately, the vast majority of those proposals were rejected. I mean the response was that given COVID now did not seem the appropriate time for a major overhaul of the system. We do expect a White Paper on this next year so I think whilst nothing immediate is happening on this, it is something to watch out for and that will hopefully be coming down the tracks.

Jane: OK. Thanks Emma. So there is a question here about not understanding the difference between there being no statutory right to sick leave but there is a right to sick pay and I am saying well doesn't the right to sick pay automatically give you a right to sick leave. It does not although it does seems counter intuitive. The point is really that when you are looking at the level of absence that is sustainable and whether an employer can dismiss, that is where it kicks in that there is no right to be off sick, there is no right have a certain level of sickness. So we sometimes in unfair dismissal cases where the employer is basically saying look we are going to be moving to dismiss very shortly. The individual says you cannot do that because I have still got x amount of months of company sick pay left. Well that is not necessarily a determining factor so that is really how there is a difference but once somebody is on sick leave then the right to sick pay kicks in.

There is a question here Emma about differentiating between how you treat an employee who gets COVID even when they are vaccinated and an employee who has refused to be vaccinated. Do you want to pick that one up?

Emma: Yes so I think you would need to be very careful about that because there may be legitimate reasons why an individual has been exempt for instance from having a vaccination. That then that brings up risks of discrimination if that individual has a protected characteristic might be that for disability related reasons they have not been able to have the vaccination. They might have a phobia of needles or something like that or there might be Religious related reasons for why they have not had the vaccination so what I would be saying is I would err on the side of caution and be careful if you were looking at doing that and differentiating.

Jane: Yes. That is right. So we have not got time to answer all of the questions but as I said there are a few we have not got to but we are up to our allotted time so we will come back to you provided that you have given your name which I can most of you have. We will be able to do that after the webinar so I hope that has been helpful. Thank you very much for joining and again as I said we will be circulating a questionnaire after the webinar. Please do take the time to fill it in and otherwise thank you very much and enjoy the rest of your day.

Emma: Thanks everyone.

Read the original article on GowlingWLG.com

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.